Supply Chain Security
Examinations of High-Risk Cargo at Foreign Seaports Have Increased, but Improved Data Collection and Performance Measures Are Needed Gao ID: GAO-08-187 January 25, 2008Customs and Border Protection's (CBP) Container Security Initiative (CSI) aims to identify and examine high-risk U.S.-bound cargo at foreign seaports. GAO reported in 2003 and 2005 that CSI helped to enhance homeland security, and recommended actions to strengthen the program. This report updates information and assesses how CBP has (1) contributed to strategic planning for supply chain security, (2) strengthened CSI operations, and (3) evaluated CSI operations. To address these issues, GAO interviewed CBP officials and reviewed CSI evaluations and performance measures. GAO also visited selected U.S. and CSI seaports, and met with U.S. and foreign government officials.
By collaborating on the development of the Department of Homeland Security's Strategy to Enhance International Supply Chain Security, and by revising the CSI strategic plan as GAO recommended, CBP has contributed to the overall U.S. strategic planning efforts related to enhancing the security for the overseas supply chain. Also, CBP reached its targets of operating CSI in 58 foreign seaports, and thereby having 86 percent of all U.S.-bound cargo containers pass through CSI seaports in fiscal year 2007--representing a steady increase in these measures of CSI performance. To strengthen CSI operations, CBP has sought to address human capital challenges and previous GAO recommendations by increasing CSI staffing levels closer to those called for in its staffing model and revising its human capital plan. However, challenges remain because CBP continues to rely, in part, on a temporary workforce; has not determined how to optimize its staffing resources; and reports difficulties in identifying sufficient numbers of qualified staff. In addition, CBP has enhanced relationships with host governments participating in CSI. However, hurdles to cooperation remain at some seaports, such as restrictions on CSI teams witnessing examinations. CBP improved its evaluation of CSI team performance at seaports, but limitations remain in the evaluation process that affect the accuracy and completeness of data collected. CBP has not set minimum technical criteria for equipment or systematically collected information on the equipment, people, and processes involved in CSI host government examinations of high-risk, U.S-bound container cargo. Also, CBP has not developed general guidelines to use in assessing the reliability of these examinations. Thus, CBP potentially lacks information to ensure that host government examinations can detect and identify weapons of mass destruction, which is important because containers are typically not reexamined in the United States if already examined at a CSI seaport. CBP refined overall CSI performance measures, but has not fully developed performance measures and annual targets for core CSI functions, such as the examination of high-risk containers before they are placed on vessels bound for the United States. These weaknesses in CBP's data collection and performance measures potentially limit the information available on overall CSI effectiveness.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-187, Supply Chain Security: Examinations of High-Risk Cargo at Foreign Seaports Have Increased, but Improved Data Collection and Performance Measures Are Needed
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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
January 2008:
Supply Chain Security:
Examinations of High-Risk Cargo at Foreign Seaports Have Increased, but
Improved Data Collection and Performance Measures Are Needed:
GAO-08-187:
GAO Highlights:
Highlights of GAO-08-187, a report to congressional requesters.
Why GAO Did This Study:
Customs and Border Protection‘s (CBP) Container Security Initiative
(CSI) aims to identify and examine high-risk U.S.-bound cargo at
foreign seaports. GAO reported in 2003 and 2005 that CSI helped to
enhance homeland security, and recommended actions to strengthen the
program. This report updates information and assesses how CBP has (1)
contributed to strategic planning for supply chain security, (2)
strengthened CSI operations, and (3) evaluated CSI operations. To
address these issues, GAO interviewed CBP officials and reviewed CSI
evaluations and performance measures. GAO also visited selected U.S.
and CSI seaports, and met with U.S. and foreign government officials.
What GAO Found:
By collaborating on the development of the Department of Homeland
Security‘s Strategy to Enhance International Supply Chain Security, and
by revising the CSI strategic plan as GAO recommended, CBP has
contributed to the overall U.S. strategic planning efforts related to
enhancing the security for the overseas supply chain. Also, CBP reached
its targets of operating CSI in 58 foreign seaports, and thereby having
86 percent of all U.S.-bound cargo containers pass through CSI seaports
in fiscal year 2007”representing a steady increase in these measures of
CSI performance.
To strengthen CSI operations, CBP has sought to address human capital
challenges and previous GAO recommendations by increasing CSI staffing
levels closer to those called for in its staffing model and revising
its human capital plan. However, challenges remain because CBP
continues to rely, in part, on a temporary workforce; has not
determined how to optimize its staffing resources; and reports
difficulties in identifying sufficient numbers of qualified staff. In
addition, CBP has enhanced relationships with host governments
participating in CSI. However, hurdles to cooperation remain at some
seaports, such as restrictions on CSI teams witnessing examinations.
CBP improved its evaluation of CSI team performance at seaports, but
limitations remain in the evaluation process that affect the accuracy
and completeness of data collected. CBP has not set minimum technical
criteria for equipment or systematically collected information on the
equipment, people, and processes involved in CSI host government
examinations of high-risk, U.S-bound container cargo. Also, CBP has not
developed general guidelines to use in assessing the reliability of
these examinations. Thus, CBP potentially lacks information to ensure
that host government examinations can detect and identify weapons of
mass destruction, which is important because containers are typically
not reexamined in the United States if already examined at a CSI
seaport. CBP refined overall CSI performance measures, but has not
fully developed performance measures and annual targets for core CSI
functions, such as the examination of high-risk containers before they
are placed on vessels bound for the United States. These weaknesses in
CBP‘s data collection and performance measures potentially limit the
information available on overall CSI effectiveness.
Figure: Containers Stacked on a Vessel at a CSI Port:
[See PDF for image]
This figure is a photograph of containers stacked on a vessel at a CSI
Port.
Source: GAO.
[End of figure]
What GAO Recommends:
GAO recommends that CBP enhance data collected on CSI team performance,
host government examinations, and related performance measures. CBP
concurred with the recommendation to enhance data on team performance.
It partially concurred with the need to enhance data on host
examinations, stating that it already conducts actions to improve such
data. However, these actions do not systematically collect data on
people, processes, or technology used by host governments to examine
U.S.-bound containers. CBP partially concurred with the need to enhance
performance measures, but stated it already captures core program
functions. We still see room for improvement.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-187]. For more information, contact
Stephen L. Caldwell at (202) 512-9610 or caldwells@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
CBP Collaborated on the DHS Strategy to Enhance International Supply
Chain Security, and Met Goals for CSI Expansion and Increased Container
Examination:
To Strengthen CSI Operations, CBP Has Taken Steps to Address Human
Capital Challenges and Enhance Host Government Relations, but
Operational Challenges Remain:
CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Performance
Measures but Still Does Not Capture Critical Information about Host
Government Examination Systems:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: Container Security Initiative Seaports:
Appendix IV: CSI Activities and Equipment:
Appendix V: CSI Performance Measures:
Appendix VI: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Major U. S. Initiatives to Secure Oceangoing Containers:
Table 2: 58 CSI seaports as of September 2007:
Table 3: CSI Performance Measures:
Figures:
Figure 1: Overview of Key Participants Involved in Shipping Containers
in the International Supply Chain:
Figure 2: Map of World with Countries Participating in CSI:
Figure 3: CSI Targeting and Examination Activities:
Figure 4: CBP Initiatives in the U.S. Supply Chain Security Strategy:
Figure 5: Number of Operational CSI Seaports and Percentage of Total
U.S-bound Containers Passing Through CSI Seaports, 2002-2007:
Figure 6: View of the Physical Layout of a Congested CSI Seaport:
Figure 7: Stacked Containers on a Shipping Vessel at a CSI Seaport:
Figure 8: CSI Process for Targeting and Examining High-risk Containers
Overseas:
Figure 9: CBP Official Using Radiation Isotope Identifier Device to
Examine Container at CSI Seaport:
Figure 10: Commercial Sample Image Produced by Nonintrusive Imaging X-
ray Equipment of a Container Loaded on a Truck Trailer:
Abbreviations:
ATS: Automated Targeting System:
C-TPAT: Customs Trade Partnership Against Terrorism:
CBP: U.S. Customs and Border Protection:
CSI: Container Security Initiative:
CSITE: Container Security Initiative Team Evaluation:
DHS: Department of Homeland Security:
DOE: Department of Energy:
NTCC: U.S. National Targeting Center Cargo:
WMD: weapons of mass destruction:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
January 25, 2008:
The Honorable Daniel K. Inouye:
Chairman:
The Honorable Ted Stevens:
Vice Chairman:
Committee on Commerce, Science, and Transportation:
United States Senate:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Carl Levin:
Chairman:
The Honorable Norm Coleman:
Ranking Member:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable John D. Dingell:
Chairman:
Committee on Energy and Commerce:
House of Representatives:
Oceangoing cargo containers play a vital role in the movement of cargo
between global trading partners. In fiscal year 2007, more than 10
million oceangoing cargo containers arrived at U.S. seaports--meaning
roughly 28,000 oceangoing containers arrived each day that year. The
terrorist attacks of 2001 heightened concerns about the ability of both
the federal government and companies participating in international
maritime commerce to identify and prevent weapons of mass destruction
from being smuggled inside cargo containers bound for the United
States. Balancing security concerns with the need to facilitate the
free flow of commerce remains an ongoing challenge for the public and
private sectors alike.
In the federal government, U.S. Customs and Border Protection (CBP),
part of the Department of Homeland Security (DHS), is charged with
managing, securing, and controlling the nation's border and in its
capacity as the frontline border security agency, plays a lead role in
facing maritime threats. CBP launched the Container Security Initiative
(CSI) in January 2002, which through partnerships with its foreign
counterparts, is designed to help protect global trade lanes by
targeting and examining container cargo that poses a threat as early as
possible in the global supply chain. As part of the program, foreign
governments allow CBP officers to be stationed at foreign seaports.
These officers use intelligence and automated risk assessment
information to target shipments to identify those at risk of containing
weapons of mass destruction (WMD) or other terrorist contraband. CBP
and host government officials share the role of assessing the risk of
U.S.-bound container cargo leaving the seaports of countries
participating in CSI. CBP officers at the CSI seaports are responsible
for targeting high-risk cargo shipped in containers and other tasks,
whereas host government customs officials examine the high-risk cargo-
-when requested by CBP--by scanning containers using various types of
nonintrusive inspection equipment, such as large-scale X-ray machines,
or by physically searching the container's contents before it travels
to the United States.
As part of its strategic plan, CBP is partnering with international
trade and security groups to develop supply chain security standards
that can be implemented by the world community. By engaging
international organizations, CBP is contributing to the development of
global security standards. Recent legislative actions intended to
further enhance maritime security also updated requirements that affect
CSI. In October 2006, Congress passed and the President signed
legislation--the Security and Accountability for Every Port Act (SAFE
Port Act) [Footnote 1]--establishing a statutory framework for CSI,
which previously had been an agency initiative not specifically
required by law. The act imposed various mandates, such as requiring
CBP to take risk factors including cargo volume into account when
designating seaports as CSI participants. In August 2007, the
Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11
Act) was enacted, which requires, among other things, 100 percent
scanning of U.S.-bound cargo containers by foreign seaports by 2012,
with possible extensions for some ports--replacing a similar provision
in the SAFE Port Act that did not have a deadline.[Footnote 2]
We have previously reported on CSI's progress in meeting its strategic
goals and objectives. Our July 2003 and April 2005 reports on CSI
acknowledged the program's important role in helping to enhance
homeland security, but we also recommended actions to enhance the
strategic planning for the program, such as better defining its goals,
objectives, and performance measures. In addition, we recommended
actions to strengthen the program's management and operations, such as
conducting human capital planning (which affects CBP staffing levels at
seaports) and establishing minimum technical capability requirements
for equipment used to examine high-risk containers.[Footnote 3]
Recognizing the importance of the CSI program, you asked us to conduct
another review. For this report, we assessed the following issues:
* How has CBP contributed to strategic planning for supply chain
security efforts and the CSI program in particular, and what progress
has been made in achieving CSI performance goals?
* How has CBP strengthened CSI operations in response to our 2005
review and what challenges, if any, remain?
* How does CBP evaluate CSI seaport operations and assess program
performance overall, and how has this process changed over time?
To address these objectives, we met with CBP officials who have program
responsibilities for CSI, and reviewed available program data and
documentation. Specifically, to review CBP's strategic planning
initiatives, we reviewed national-level strategic planning documents
and those created for DHS, CBP, and CSI. To determine CBP's progress in
achieving its CSI program goals, we reviewed CBP's statistical data on
container cargo and CSI program activities. To learn about how CBP has
strengthened its operations, we reviewed our previous assessments of
the CSI program, and examined CBP's efforts to implement our three
prior recommendations. To assess CBP's progress, we met with CBP
officials at the U.S. National Targeting Center - Cargo (NTCC) in
Virginia and three domestic seaports in different geographical
locations and representing varying volumes of container traffic.
[Footnote 4] We also visited six CSI seaports located overseas that
were selected based on several factors, including geographic and
strategic significance, volume of container traffic, and when CSI
operations began at the seaport. The results from our visits to
seaports provided examples of CBP and host government operations but
cannot be generalized beyond the seaports visited because we did not
use statistical sampling techniques in selecting the seaports.
To determine what progress CBP has made in strengthening its tools for
monitoring and measuring the progress of the CSI program, we reviewed
the performance measures presented in the CSI strategic plan against
criteria developed by the Office of Management and Budget and GAO. We
also reviewed a nonrepresentative sample of CSI team evaluations. While
these documents provided examples about program evaluation methods and
CSI program operations, and generally corroborated our seaport site
visit observations, our findings cannot be generalized to the program
as a whole. We conducted this performance audit from May 2006 through
January 2008 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives. A detailed
discussion of our scope and methodology is contained in appendix I.
Results in Brief:
CBP contributed to a new strategic planning document to guide efforts
to secure the international supply chain, updated the CSI strategic
plan, and reported achieving key CSI goals by increasing both the
number of CSI locations and the proportion of total U.S.-bound
containers passing through CSI seaports. By supporting the development
of the Strategy to Enhance International Supply Chain Security that DHS
was required to produce in accordance with the SAFE Port Act, and by
revising and enhancing the strategic plan for CSI, as we had previously
recommended, CBP has contributed to overall strategic planning efforts
related to supply chain security. The supply chain security strategy,
issued in July 2007, delineates the supply chain security roles,
responsibilities, and authorities of federal, state, local, and private
sector entities, and describes how CBP's portfolio of initiatives to
address supply chain security, including CSI, is coordinated throughout
the supply chain. As to achieving CSI performance goals, in fiscal year
2007, CBP reached its targets of operating CSI in 58 foreign seaports
and having 86 percent of all U.S.-bound containers passing through CSI
seaports--where, according to CBP, there is an opportunity for the high-
risk cargo to be examined at foreign seaports before reaching the
United States. These results represent a continued increase in both of
these measures of CSI performance since CSI's inception in 2002. Also,
CBP reported increases in the number of high-risk cargo containers
examined by host governments at CSI seaports.
To strengthen CSI operations over the last 2 years, CBP has sought to
address human capital challenges and enhance relationships with host
governments participating in CSI, but operational challenges remain.
Our 2005 CSI report noted that CBP had not achieved its goal of
targeting all U.S.-bound containers passing through CSI seaports for
high-risk cargo before they depart for the United States because, in
part, the agency had not been able to place enough staff at some CSI
seaports. CBP has subsequently taken steps to implement related
recommendations, including increasing overall staffing levels just
above the 203 positions called for in its staffing allocation model by,
among other things, adding 125 permanent staff to CSI seaports and 15
staff to the NTCC, resulting in a parallel increase in the volume of
container cargo that is targeted. Nevertheless, CBP continues to rely,
in part, on a temporary workforce at CSI seaports and the NTCC; has yet
to determine how to optimize its staffing resources even as the CSI
program expands; and reports difficulties in identifying sufficient
numbers of qualified individuals to hire for the program. In addition,
findings from our CSI port site visits and our review of select CSI
evaluations conducted by CBP suggest that relationships with host
governments have improved over time, leading to increased information
sharing between governments and a bolstering of host government customs
and port security practices, among other things. However, we also found
that levels of collaboration between U.S. and host government officials
varied across CSI seaports and we identified hurdles to cooperation
between CSI teams and their counterparts in the host government, such
as host country legal restrictions that CBP officials said prevent CSI
teams from observing examinations. CBP also continues to face
logistical difficulties inherent in a seaport environment, often
outside of its control, such as high-risk container cargo that is
infeasible to access for examination.
CBP has enhanced how it collects data about CSI operations by
strengthening its approach to on-site evaluations of teams of CBP
officers at CSI seaports and has refined certain programwide
performance measures, but weaknesses remain in CBP's evaluation and
performance measurement efforts. Also, CBP lacks a process for
systematically gathering information on the equipment, people, and
processes used by host governments to examine U.S.-bound cargo
containers identified as high-risk. Specifically, CBP has recently
improved its process for conducting evaluations at CSI seaports by,
among other things, testing the proficiency of the CBP officers who
must identify high-risk cargo, and by introducing an electronic tool
that enables CBP evaluation teams to systematically record their
evaluative data. However, evaluators do not always use the data
collection tools as intended, which makes it difficult for CBP to
ensure that evaluations are consistently carried out or that evaluative
data are reliable for management decisions. Also evaluators do not
always follow up on recommendations made in previous evaluation
reports--so CBP cannot ensure that previously identified problems have
been addressed. Also, CBP has not set minimum technical capability
criteria for equipment used at CSI seaports as we recommended in April
2005 and as required under the SAFE Port Act for CSI and the 9/11 Act
for future 100 percent scanning of U.S.-bound containers. Without such
criteria and systematically collected information on equipment, people
and processes involved in each host government's cargo, CBP does not
have a sound basis for determining the reliability of the examination
systems used at CSI seaports, which is of particular importance because
only a small fraction of U.S.-bound high-risk containers are reexamined
upon arrival in the United States. With respect to assessing CSI
performance overall, over the past 2 years, CBP has revised its
performance measurement system to provide decision makers with more
accurate indicators of the program's progress--by setting some specific
performance targets and modifying some existing measures--and to
reflect CSI's continuing maturation. However, we identified limitations
with the CSI performance measures, such as the omission of measures for
a key core CSI function, the lack of annual performance targets, and
misleading or confusing methods for calculating several performance
measures. These limitations may potentially make it difficult for CBP
and DHS managers and Congress to appropriately provide program
oversight.
We are recommending that the Secretary of Homeland Security direct the
Commissioner of CBP to take actions to help ensure that the agency has
the information necessary to ensure that CSI is operating efficiently
and effectively. Specifically, we are recommending that CBP (1)
strengthen it's process for evaluating CSI teams at overseas ports by
maintaining evaluation data, ensuring evaluation teams follow
procedures, and monitoring the completions of recommendations from
previous evaluations; (2) improve, in collaboration with host
government officials, the information gathered about the host
governments' examination systems to determine their reliability and
whether mitigating actions or incentives are necessary to provide the
desired level of security; and (3) enhance CSI performance measurement
processes to better assess CSI performance overall.
We provided a draft of this report to the Department of State and DHS
for their review and comment. The Department of State did not provide
written comments but provided technical comments, which have been
incorporated into the report as appropriate. DHS provided written
comments--incorporating comments from CBP--on December 20, 2007, which
are presented in Appendix II. In its written comments, DHS and CBP
concurred with our recommendation on strengthening its process for
evaluating CSI teams at overseas locations. CBP partially concurred
with our recommendation to improve information gathered about host
government examination systems. CBP agreed on the importance of an
accepted examination process and noted it continues to take steps to
address improvements in the information gathered about host
governments' examination systems at CSI ports by working directly with
host government counterparts, through the World Customs Organization,
and providing capacity building training and technical assistance.
While CBP does engage in capacity building with some CSI host
governments, it does not systematically collect or assess information
on the people, processes, or technology used by these host governments
to examine high-risk U.S.-bound containers, and thus has limited
assurance that CSI host government examination systems can detect and
identify WMD. Finally, CBP partially concurred with our recommendation
to enhance CSI performance measures to better assess CSI performance
overall. CBP stated that it believes its current measures address core
program functions of targeting and collaboration with host governments
to mitigate or substantiate the risk of a maritime container destined
for the United States. We disagree. As discussed in this report, a core
element of the CSI program, specifically the extent to which U.S.-bound
containers carrying high-risk cargo are examined at CSI seaports, is
not addressed through CBP's performance measures.
Background:
Vulnerabilities of Containers in the International Supply Chain:
Seaports are critical gateways for the movement of commerce through the
international supply chain. The facilities, vessels, and infrastructure
within seaports, and the cargo passing through them, all have
vulnerabilities that terrorists could exploit. The containers carrying
goods that are shipped in oceangoing vessels are of particular concern
because they can be filled overseas at many different locations and are
transported through complex logistics networks before reaching U.S.
seaports.
In addition, transporting such a shipping container from its
international point of origin to its final destination involves many
different participants and many points of transfer. The materials in a
container can be affected not only by the manufacturer or supplier of
the material being shipped, but also by carriers who are responsible
for getting the material to a port and by personnel who load containers
onto the ships. Others who interact with the cargo or have access to
the records of the goods being shipped include, among others, exporters
who make arrangements for shipping and loading, freight consolidators
who package disparate cargo into containers, and forwarders who manage
and process the information about what is being loaded onto the ship.
Figure 1 illustrates many of the key participants and points of
transfer involved from the time that a container is loaded for shipping
to its arrival at the destination seaport and ultimately the importer.
Figure 1: Overview of Key Participants Involved in Shipping Containers
in the International Supply Chain:
[See PDF for image]
This figure contains three photographs as well as the following data:
Export Side:
Exporter;
Freight consolidater;
Inland carrier (truck, rail, smart vessel);
Terminal operator;
Freight forwarder;
Customs Inspector;
Photograph: Containerized goods ready for shipment;
Photograph: Shipment aboard ocean carrier.
Import Side:
Customs broker;
Customs inspector;
Terminal operator;
Inland carrier (truck, rail, smart vessel);
Importer;
Photograph: Arrival at receiving port.
Source: GAO, DHS.
[End of figure]
Several studies on maritime security conducted by federal, academic,
nonprofit, and business organizations have concluded that the movement
of oceangoing cargo in containers is vulnerable to some form of
terrorist action, largely because of the movement of cargo throughout
the supply chain. Every time responsibility for cargo in containers
changes hands along the supply chain there is the potential for a
security breach, and thus, vulnerabilities exist that terrorists could
take advantage of by placing a WMD into a container for shipment to the
United States. While there have been no known incidents of containers
being used to transport WMDs, criminals have exploited containers for
other illegal purposes, such as smuggling weapons, people, and illicit
substances, according to CBP officials. Finally, while CBP has noted
that the likelihood of terrorists smuggling WMD into the United States
in cargo containers is low, the nation's vulnerability to this activity
and the consequences of such an attack are potentially high. In 2002,
Booz Allen Hamilton sponsored a simulated scenario in which the
detonation of weapons hidden in cargo containers shut down all U.S.
seaports over a period of 12 days. The results of the simulation
estimated that the port closure could result in a loss of $58 billion
in revenue to the U. S. economy, along with significant disruptions to
the movement of trade.
Efforts to Secure Containers in the International Supply Chain:
The federal government has taken many steps to secure the supply chain,
including the cargo in containers destined for the United States. While
CBP officials at domestic seaports continue efforts to identify and
examine high-risk imports arriving in containers, CBP's post-September
11 strategy also involves focusing security efforts beyond U.S. borders
to target and examine high-risk cargo before it enters U.S. seaports.
CBP's strategy is based on a layered approach of related initiatives
that attempt to focus resources on potentially risky cargo shipped in
containers while allowing other containers carrying cargo to proceed
without unduly disrupting commerce into the United States. CBP has
initiated most of these efforts, shown in table 1. However, the
Department of Energy (DOE) has led U.S. efforts to detect radiation in
cargo containers originating at foreign seaports.
Table 1: Major U. S. Initiatives to Secure Oceangoing Containers:
Initiative and year introduced: Automated Targeting System, (ATS), 1995
(prototype);
Department: DHS;
Description: CBP uses this computerized decision support tool to review
documentation, including electronic manifest information submitted by
ocean carriers on all cargo destined for the United States to help
identify shipments requiring additional scrutiny. ATS utilizes complex
mathematical models with weighted rules that assign a risk score to
each shipment based on manifested information. CBP officers review the
rule firings that support the ATS score to help them make decisions on
the extent of documentary review or examination to be conducted.
Initiative and year introduced: 24-hour rule, 2002;
Department: DHS;
Description: CBP generally requires ocean carriers to electronically
transmit cargo manifests to CBP's Automated Manifest System 24 hours
before the U.S.-bound cargo is loaded onto a vessel at a foreign
seaport. Carriers and importers are to provide information to CBP that
is used to strengthen how ATS assigns risk scores. The cargo manifest
information is submitted by ocean carriers on all arriving cargo
shipments, and entry data (more detailed information about the cargo)
are submitted by brokers.
Initiative and year introduced: Container Security Initiative (CSI),
2002;
Department: DHS;
Description: CSI places staff at participating foreign seaports to work
with host country customs officials to target and examine high-risk
cargo to be shipped in containers for weapons of mass destruction
before they are shipped to the United States. CBP officials identify
the high-risk containers and request that their foreign counterparts
examine the contents of the containers.
Initiative and year introduced: Customs-Trade Partnership Against
Terrorism (C-TPAT), 2002;
Department: DHS;
Description: CBP develops voluntary partnerships with members of the
international trade community comprised of importers; customs brokers;
forwarders; air, sea, and land carriers; and contract logistics
providers. Private companies agree to improve the security of their
supply chains in return for various benefits, such as a reduced
likelihood that their containers will be examined.
Initiative and year introduced: Megaports Initiative, 2003;
Department: DOE;
Description: DOE installs radiation detection equipment at key foreign
seaports, enabling foreign government personnel to use radiation
detection equipment to screen shipping containers entering and leaving
these seaports, regardless of the containers' destination, for nuclear
and other radioactive material that could be used against the United
States and its allies.
Initiative and year introduced: Secure Freight Initiative, 2007;
Department: DHS, DOE;
Description: Pilot program at selected CSI seaports to scan 100 percent
of U.S.-bound cargo containers for nuclear and radiological materials
overseas using integrated examination systems that couple nonintrusive
inspection equipment and radiation detection equipment.
Source: GAO.
Note: Cargo manifests are prepared by the ocean carrier and are
composed of bills of lading for each shipment of cargo loaded on a
vessel to describe the contents of the shipments. The bill of lading
includes a variety of other information, such as the manufacturer of
the cargo and the shipping line.
[End of table]
In January 2002, CBP began CSI to target container cargo at overseas
seaports so that high-risk cargo could be examined prior to departure
for the United States. More recently, Congress passed legislation
affecting the CSI program, including (1) the SAFE Port Act enacted in
October 2006 that established a statutory framework for CSI and, among
other things, required a pilot program, now known as the Secure Freight
Initiative, to determine the feasibility of 100 percent scanning of
U.S.-bound cargo containers at foreign seaports; and (2) the 9/11 Act
enacted in August 2007, that, among other things, requires by 2012, the
scanning of all U.S.-bound containers at foreign seaports with
potential exceptions if a seaport cannot meet that deadline.
For the CSI program, CBP officials stated that DHS expended about $138
million and $143 million, respectively for fiscal years 2006 and 2007.
The President's budget for fiscal year 2008 requested $156 million for
CSI. CSI is now operating at 58 seaports in 33 foreign countries, as
shown in figure 2. Appendix III lists the specific CSI seaports.
Figure 2: Map of World with Countries Participating in CSI:
[See PDF for image]
This figure is a map of the world with countries participating in CSI
indicated as follows:
South, North and Central America, and the Carribean:
Argentina;
Bahamas;
Brazil;
Canada;
Columbia;
Dominican Republic;
Honduras;
Jamaica;
Panama.
Europe:
Belgium;
France;
Germany;
Greece;
Israel;
Italy;
Netherlands;
Portugal;
Spain;
Sweden;
United Kingdom.
Africa, Middle East:
Egypt;
Oman;
South Africa;
United Arab Emirates.
Far East, South and Southeast Asia, Australia and the Pacific:
China;
Japan;
Korea (Republic of);
Malaysia;
Pakistan;
Singapore;
Sri Lanka;
Taiwan;
Thailand.
Source: GAO (map art), Map Resources (map), CBP (data).
[End of figure]
Core Elements and Security Activities of CSI Program:
According to CBP, the three core elements of CSI include (1) CBP
identifying high-risk containers; (2) CBP requesting, where necessary,
that host governments examine high-risk containers before they are
shipped; and (3) host governments conducting examinations of high-risk
containers. To integrate these elements into CSI operations, CBP
negotiated and entered into bilateral, nonbinding arrangements with
foreign governments, specifying the placement of CBP officials at
foreign seaports and the exchange of information between CBP and
foreign customs administrations. To participate in CSI, a host nation
must meet several criteria developed by CBP. The host nation must
utilize (a) a seaport that has regular, direct, and substantial
container traffic to seaports in the United States; (b) customs staff
with the capability of examining cargo originating in or transiting
through its country; and (c) nonintrusive inspection equipment with
gamma or X-ray capabilities and radiation detection equipment.
Additionally, each potential CSI port must indicate a commitment to (d)
establish an automated risk management system for identifying
potentially high-risk container cargo; (e) share critical data,
intelligence, and risk management information with CBP officials; (f)
conduct a seaport assessment to ascertain vulnerable links in a port's
infrastructure and commit to resolving those vulnerabilities; and (g)
maintain a program to prevent, identify, and combat breaches in
employee integrity.
As part of the arrangements with foreign governments participating in
CSI, CBP most often stations teams of CBP officers at each foreign
seaport to conduct CSI activities in collaboration with host government
customs officials. While the number of CBP officers stationed at CSI
seaports varies by location, typically a CSI team consists of (1) a CSI
team leader, who manages the team and monitors the relationship with
the host country; (2) CBP officers, who target high-risk cargo and
observe (where possible) the host government's examination of
containers carrying the cargo; (3) an intelligence research specialist,
who assimilates data to support timely and accurate targeting of
containers; and (4) a special agent responsible for CSI-related
investigations at the seaport. According to CBP, it is ideal for the
CSI team to be located in close physical proximity with host government
customs counterparts to facilitate collaboration and information
sharing. However, CBP officials also stated that the agency uses CBP
officers stationed at the NTCC as needed to support the CBP officers
located at the CSI seaports. The CBP officials at NTCC assist the CSI
teams at high-volume seaports to ensure all containers that pass
through CSI seaports are targeted to identify high-risk container
cargo; carry out CSI targeting responsibilities for CSI seaports that
do not have CBP officials stationed there; and, according to CBP
officials, conduct targeting for U.S.-bound container cargo that does
not pass through CSI seaports using national sweeps to identify high-
risk container cargo.
At CSI seaports, CBP officers share responsibilities with host
governments' customs officials to target and examine high-risk
container cargo. Figure 3 describes the activities carried out by CBP
officers and host government customs officials, respectively, to target
and examine high-risk container cargo at CSI seaports.[Footnote 5]
Figure 3: CSI Targeting and Examination Activities:
[See PDF for image]
This figure is a combination of descriptions of CSI Targeting and
Examination Activities, with accompanying photographs, as follows:
Targeting high-risk container shipments:
CBP uses ATS to electronically review data about U.S.-bound shipments
to produce a risk score, a process CBP refers to as screening. CBP
officers review the ATS risk scores and may consider additional
information or collaborate with host government officials to identify
high-risk shipments with a nexus to terrorism”a process referred to as
targeting.CBP officials make a final determination about which
containers are high risk and will be referred to host government
customs officials for examination.
Photograph:
CBP official conducting targeting activities at the NTC.
Examining high-risk container shipments:
CBP officials request that host government officials examine containers
with high-risk shipments to detect WMD or other items with a nexus to
terrorism. Examining a container involves using nonintrusive inspection
equipment, radiation detection equipment, or both to scan the
container‘s contents. Typically, the radiation detection equipment is
used, then large scale nonintrusive inspection equipment, to scan the
container‘s contents. The results of the scan will influence whether or
not CBP requests that the host government conduct a physical search,
during which a container is opened and its contents are removed for
review.
Photograph:
Container scanned with non-intrusive imaging x-ray equipment at a CSI
port.
Source: GAO and CBP.
[End of figure]
CBP Collaborated on the DHS Strategy to Enhance International Supply
Chain Security, and Met Goals for CSI Expansion and Increased Container
Examination:
CBP has undertaken strategic planning to guide efforts to secure the
international supply chain and, more specifically, to manage the CSI
program. CBP contributed to an international supply chain security
strategy DHS recently issued that builds on DHS's existing strategic
framework for maritime security. In 2006 CBP enhanced its strategic
plan for CSI by including three key elements missing from the plan's
previous iteration, and has achieved two performance goals by expanding
CSI locations and increasing the percentage of total U.S.-bound
containers that pass through CSI seaports. Concurrently, CBP reported
an increase in the number of high-risk containers examined by host
governments participating in CSI.
Recently Issued International Supply Chain Security Strategy Builds on
DHS's Existing Strategic Framework for Maritime Security:
When it published the Strategy to Enhance International Supply Chain
Security in July 2007, DHS filled a gap that had existed between broad
national strategies and program-specific plans in the federal
government's strategic planning framework for maritime security. Over
the last 5 years, DHS has made progress in developing a multilayered
strategic framework for securing the maritime domain, including the
international supply chain. This framework consists of high-level
national strategies, such as the National Strategy for Maritime
Security and the Maritime Commerce Security Plan, which describe the
federal government's broad approach to maritime security. These plans
are supplemented by a related hierarchy of documents that includes the
DHS strategic plan, the CBP strategic plan, and the CSI program's own
strategic plan.
Prior to July 2007, the federal government's maritime security
framework touched on many specific aspects of maritime trade and
commerce, such as how the CSI program contributes to securing
containers bound for U.S. seaports. However, it did not provide a
detailed description of how federal, state, and local authorities were
to collaborate on supply chain security specifically. In addition,
Congress included a provision in the SAFE Port Act of 2006 requiring
DHS to develop a strategic plan to enhance the security of the
international supply chain. Moreover, the DHS fiscal year 2007
appropriation act withheld $5 million from DHS until a comprehensive
strategic plan for port, cargo, and container security, which included
specific elements, had been submitted to specified congressional
committees. In response, CBP contributed to the Strategy to Enhance the
International Supply Chain Security, which DHS developed and issued in
July 2007. According to DHS, the supply chain security strategy is not
meant to replace other strategic planning documents, but seeks to
harmonize the goals of the various plans and programs into a
multilayered, unified approach that can be further developed by DHS
components, including CBP.
This new strategic planning document for supply chain security
delineates the supply chain security roles, responsibilities, and
authorities of federal, state, local, and private sector entities. The
strategy seeks to build on the current multilayered strategic framework
for maritime security by establishing an overarching framework for the
secure flow of cargo through the supply chain--from point of origin to
final destination. The strategy describes how CBP's portfolio of supply
chain security initiatives--including CSI, C-TPAT, cargo screening
using ATS, the 24-hour rule, and the use of nonintrusive inspection
equipment to examine containers--addresses the various stages in the
supply chain. In addition, the strategy provides details on how other
organizations' programs or efforts--such as DOE's Megaports initiative,
which places radiation detection equipment at foreign seaports--
contribute to different aspects of supply chain security. Figure 4
describes the major components of the supply chain and the CBP
initiatives that operate to secure them.
Figure 4: CBP Initiatives in the U.S. Supply Chain Security Strategy:
[See PDF for image]
This figure is a flow-chart of CBP Initiatives in the U.S. Supply Chain
Security Strategy, depicting the following data:
Supply chain:
* Packaging and cargo origination, Empty container;
* Shipment consolidation, Storage;
* Port of origin, Initiatives to secure the supply chain:
- C-TPAT;
- Cargo screening/ATS;
- 24-hour rule;
- CSI;
- SFI;
* Transshipment port;
* Port of entry;
* Storage, Shipment deconsolidation, Initiatives to secure the supply
chain:
- Examination of high-risk containers at U.S. seaports.
* Destination.
Source: GAO.
[End of figure]
CBP Added Key Elements to the CSI Strategic Plan in Response to our
2005 Recommendation:
At the program level, CBP has revised its CSI strategic plan, an
important component of the DHS strategic framework described above,
incorporating three critical elements that were absent from the plan's
previous iteration. In our April 2005 report on CSI, we reported that
the CSI strategic plan lacked three of the six key elements identified
by the Government Performance and Results Act of 1993 for an agency
strategic plan, including descriptions of:
1. how performance goals and measures are related to program objectives,
2. the external factors beyond the control of CBP that could affect the
achievement of program objectives, and:
3. the evaluations that CBP conducts to monitor CSI.[Footnote 6]
We noted that, given the importance of having an effective strategic
plan for the program, we would continue to monitor CBP's progress in
refining the plan. CBP has subsequently taken steps to address our
concerns. In the most recent version of the plan, released in August
2006, CBP included information in three areas, as we had previously
recommended. First, the CSI strategic plan links each performance
measure to the strategic goal it supports. In addition, the plan
describes how some performance measures were designed to act as proxies
for program objectives that can be difficult to measure. Second, the
CSI strategic plan also lists a variety of external factors that have
the potential to influence CSI operations, including regional
conflicts, organized crime, and changes in the political administration
of a foreign government participating in CSI. Finally, the revised plan
provides an explanation of the CSI team evaluation process, thus
addressing the third issue identified in our April 2005 report. We
discuss performance measure outcomes, other external factors, and CBP's
evaluation process in greater detail later in this report.
CBP Met Performance Goals to Expand Number of CSI Seaports and to
Increase Proportion of Total U.S.-bound Containers Passing Through CSI
Seaports:
The August 2006 CSI strategic plan set specific goals for expanding the
number of seaports participating in CSI, and set targets for related
increases in the percentage of total U.S.-bound containers that pass
through CSI seaports. As of September 2007, CBP reported meeting its
goals in both of these areas. Specifically, the plan called for CBP to
expand CSI program operations from 40 to 50 seaports by the end of
fiscal year 2006, and to 58 seaports by the end of fiscal year 2007
(see appendix III for a complete list of participating seaports).
Having reached its goal of 58 CSI seaports, CBP officials reported it
currently does not have plans to add other CSI seaports, as the costs
associated with expanding the program further would outweigh the
potential benefits. In addition, the plan set a performance target that
by 2010, 86 percent of all U.S.-bound container cargo was to pass
through CSI seaports.[Footnote 7] According to CBP, when U.S.-bound
containers pass through CSI seaports there is an opportunity for high-
risk cargo to be examined at the foreign seaport by the host
governments participating in CSI, rather than upon arriving at a U.S.
seaport. CBP reported that about 73 percent and about 80 percent of
total U.S.-bound container cargo passed through CSI seaports in fiscal
years 2005 and 2006, respectively, and that it reached its 2010 goal
early by reaching approximately 86 percent by the end of fiscal year
2007. Figure 5 shows that as the number of operational CSI seaports
expanded from 2002 to 2007, the proportion of total U.S.-bound
container cargo passing through CSI seaports also continued to
increase.[Footnote 8]
Figure 5: Number of Operational CSI Seaports and Percentage of Total
U.S-bound Containers Passing Through CSI Seaports, 2002-2007:
[See PDF for image]
This figure is a multiple line graph illustrating the number of
operational CSI Seaports and percentage of total U.S-bound containers
passing through CSI Seaports, 2002-2007. The left vertical axis of the
graph represents number of CSI ports from 0 to 90. The right vertical
axis of the graph represents percentage of containers from 0 to 90. The
horizontal axis of the graph represents fiscal years from 2002 to 2007.
The following data is depicted:
Fiscal year: 2002;
Number of seaports conducting CSI operations: 4;
Percentage of total U.S.-bound containers passing through at CSI ports:
5%.
Fiscal year: 2003;
Number of seaports conducting CSI operations: 16;
Percentage of total U.S.-bound containers passing through at CSI ports:
39%.
Fiscal year: 2004;
Number of seaports conducting CSI operations: 26;
Percentage of total U.S.-bound containers passing through at CSI ports:
45%.
Fiscal year: 2005;
Number of seaports conducting CSI operations: 40;
Percentage of total U.S.-bound containers passing through at CSI ports:
73%.
Fiscal year: 2006;
Number of seaports conducting CSI operations: 50;
Percentage of total U.S.-bound containers passing through at CSI ports:
80%.
Fiscal year: 2007;
Number of seaports conducting CSI operations: 58;
Percentage of total U.S.-bound containers passing through at CSI ports:
86%.
Source: GAO presentation of CBP data.
[End of figure]
In implementing the CSI program and reaching its goal of 58 operational
CSI seaports, CBP selected foreign seaports to participate in the
program in three phases. CBP officials reported using the following
general selection criteria for each phase as follows:[Footnote 9]
* Most of the 23 phase I seaports were selected because they shipped
the highest volume of U.S.-bound container cargo.[Footnote 10]
* The 19 phase II seaports were selected based on factors such as cargo
volume, strategic threat factors and the foreign government's level of
interest in CSI.
* The 16 phase III seaports were selected using the phase II criteria
as well as diplomatic or political considerations, such as the requests
of foreign governments already participating in CSI.
As CBP expanded the number of CSI seaports and increased the proportion
of total U.S.-bound container cargo passing through CSI seaports, the
agency also achieved increases in security activities that occur at CSI
seaports--targeting (CBP screens container cargo with ATS to produce
risk scores and conducts additional review or research to ascertain
risk levels) and examining high-risk container cargo (host government
officials examine high-risk containers by scanning with nonintrusive
inspection equipment or by physically searching the container). As of
September 2007 CBP reported fully targeting 100 percent of all U.S.-
bound container cargo to identify high-risk cargo as required by the
SAFE Port Act.[Footnote 11] In addition, foreign governments
participating in CSI have examined an increasing amount of high-risk
container cargo as a growing proportion of total U.S.-bound containers
pass through CSI seaports. In keeping with the CSI program's risk-based
approach, CBP currently does not request that the host governments
examine all U.S.-bound containers passing through the CSI seaports,
just those that CBP officers have determined to be high-risk. In fiscal
year 2006, the number of high-risk containers examined by host
government officials at CSI seaports increased by 77 percent from the
previous year to almost 71,000 containers. In fiscal year 2007,
examinations continued to increase, reaching almost 137,000 containers.
Moreover, in fiscal year 2007 CBP reported that host government
officials examined approximately 96 percent of the container cargo
referred for examination. CBP reported that about 4 percent of the
referrals did not lead to examinations (about 5,600 requests) because
(1) logistical difficulties arose, such as the container had already
been loaded on the shipping vessel (about 5,200 requests),or (2) the
host government denied the request (fewer than 400 requests).
To Strengthen CSI Operations, CBP Has Taken Steps to Address Human
Capital Challenges and Enhance Host Government Relations, but
Operational Challenges Remain:
CBP has made various operational improvements to CSI, though challenges
remain. First, CBP has revised its human capital plan and added
permanent staff at CSI seaports, though it reports difficulties in
hiring and deploying qualified staff. Second, CBP's relations with CSI
host governments we spoke to that conduct cargo examinations have
improved over time, though access to key examination-related
information and processes is limited by host governments at some CSI
seaports. And finally, CBP's ability to conduct CSI program activities
involves logistical challenges that are inherent to many seaport
environments, such as those that are densely packed with equipment and
personnel.
CBP Has Increased Permanent Staffing Levels at CSI Seaports, but Has
Yet to Determine Optimum Distribution of Staff to Ensure All Critical
Operations Are Performed:
The ability of the CSI program to operate in accordance with its
mission and objectives depends, in part, on the success of its human
capital strategy--and CBP's ability to manage and deploy staff in a way
that ensures that critical security functions are performed. Our April
2005 report on CSI noted that although CBP's goal is to target all U.S.-
bound cargo shipped in containers at CSI seaports before they depart
for the United States, the agency had not been able to place enough
officers at some CSI seaports to do so. Specifically, CBP had developed
a CSI staffing allocation model to determine the staff needed to target
container cargo. However, at some CSI seaports CBP had been unable to
staff the CSI teams at the levels called for in the CSI staffing
model.[Footnote 12] We noted that CBP's staffing model had not, at the
time, considered whether some of the targeting functions could be
performed in the United States. We recommended that CBP revise its
staffing model to consider what functions need to be performed at CSI
seaports and what functions can be performed in the United States,
optimum levels of staff at CSI ports, and the cost of locating CBP
targeters overseas at CSI seaports instead of the United States.
CBP has subsequently taken several steps to increase the number of CSI
officers and to implement our 2005 recommendations. For example, in
response to our concerns about staffing imbalances across seaports and
shortages at the highest-volume seaports, CBP has increased staffing
levels, bringing them closer to those called for in its staffing model--
resulting in a parallel increase in the volume of container cargo that
is targeted. Also, CBP has added 15 staff to CSI targeting duty at the
NTCC since 2005, composed of temporary and permanent officers. In
addition, in fiscal year 2007 CBP deployed an additional 125 permanent
and 68 temporary officers to CSI seaports. Considering the officers at
both CSI seaports and the NTCC, as of November 2007, CBP had deployed
209 CSI officers, which exceeds the 203 called for in the CSI staffing
model. As a result of these efforts, CBP officials told us that they
had increased their targeting of U.S.-bound container cargo from 65
percent in April 2005 to 100 percent in September 2007.
The agency also developed cost estimates for placing a mix of permanent
and temporary staff at CSI seaports (with permanent staff costing about
$330,000 per year and temporary staff about $275,000 per year) in
response to our recommendation. CBP reported that the advantages of
placing officers at CSI seaports on a permanent rather than a temporary
basis include greater opportunities for enhanced communication and
coordination with host governments, and less disruption due to fewer
rotations into and out of the country. At one CSI port that we visited,
host government customs officials told us that the presence of
permanent staff facilitated increased information sharing, which over
time could lead to a decrease in unnecessary examinations.
Despite the progress it has made, CBP continues to face staffing
challenges. CBP officials told us, for example, they continue to face
challenges in obtaining sufficient numbers of qualified officers to be
permanently deployed at CSI seaports. For example, CBP officials
reported that only 9 qualified applicants applied for 40 permanent
positions at CSI seaports. Officials told us that CSI must compete for
staff with targeting or seaport experience with other CBP programs or
positions, such as C-TPAT or other programs that operate at the NTCC.
To fill open positions at CSI seaports, CBP officials reported that in
some instances officers have been deployed who have not received all of
the required training. In addition, CBP evaluation data we reviewed
showed examples of CBP officers at CSI seaports lacking key skills,
such as the ability to target proficiently or communicate in the local
language.
In addition, CBP has taken action to enhance its human capital planning
process for CSI, but has not yet included important factors in its
staffing allocation model. As we reported in 2005, one of the features
of the CSI staffing model that may contribute to staffing imbalances
was its reliance on placing officers overseas at CSI seaports. It did
not consider what functions could be done in the United States. In May
2006, in response to our recommendations, CBP issued a human capital
plan that did not specify that CSI targeting positions be located at
CSI seaports, thus recognizing that officers could support CSI seaports
from the NTCC in the United States. CBP officers assigned to the NTCC
perform many of the same roles as officers at CSI seaports, including
reviewing bills of lading.[Footnote 13] CBP officers at the NTCC review
bills of lading for high-volume seaports where the placement of the
number of CSI officers required to review all bills of lading is
unfeasible.[Footnote 14] In addition, according to CBP officials, CBP
officers at the NTCC review bills of lading for U.S.-bound cargo from
CSI seaports where no CBP officers are stationed. Though CBP's 2006
human capital plan generally recognizes that some CSI functions can be
performed at either a CSI seaport or at the NTCC, the staffing
allocation model used to calculate the number of targeters necessary to
review bills of lading for each CSI port does not include factors that
specify where these positions should be located.
In addition, CBP's staffing allocation model does not take into account
activities other than targeting--such as witnessing host government
examinations--that CSI officers perform at CSI seaports. According to
CBP, the agency stations as many of the total officers needed as
possible at the CSI seaports, but if the number of officers needed is
higher than the number of officers allowed by the host government or
available to be stationed in the seaport, then the remainder of the
officers target from the NTCC.[Footnote 15] However, we found that CBP
has still not systematically determined the optimal number of officers
that need to be physically located on-site at CSI seaports to carry out
duties that require an overseas presence (such as coordinating with
host government officials or witnessing the examinations they conduct)
as opposed to other duties that could be performed off-site in the
United States (such as reviewing bills of lading and databases). Also,
CBP's revised CSI human capital plan does not include costs related to
placing temporary staff at the NTCC and thus does not have the data
needed to conduct a cost-benefit analysis for determining the optimal
location for its CSI officers.[Footnote 16] As we noted in our 2002
report on a staffing framework for use at U.S. embassies, federal
agencies should consider factors such as cost and physical security of
foreign operations and consider options such as relocating staff to the
United States, as part of their framework for determining the right
number of staff to be placed overseas.[Footnote 17] Determining optimal
staffing levels is particularly important in light of ongoing
challenges CBP reports facing to identify sufficient numbers of
qualified individuals to hire for the program, and in light of the
program's recent expansion to additional seaports around the world.
While CBP has taken steps to implement the recommendations from our
April 2005 report, further action is needed regarding the staffing
allocation model. Specifically, as we recommended in 2005, the model
should be revised to consider (1) what functions need to be performed
at CSI seaports and what functions can be performed in the United
States, (2) the optimum levels of staff needed at CSI seaports to
maximize the benefits of targeting and examination activities in
conjunction with host nation customs officials, and (3) the cost of
locating targeting positions overseas at CSI seaports instead of in the
United States.
Level of Collaboration between U.S. and Host Customs Officials Has
Improved, but Challenges Remain at Some CSI Seaports:
CSI's strategic plan emphasizes the importance of CBP's continued
efforts to foster partnerships with foreign customs officials at CSI
seaports to improve CSI operations. Specifically, according to CBP
headquarters officials, when CSI teams stationed at foreign seaports
develop strong interpersonal relations with foreign government
officials, it leads to increased trust and information sharing and thus
improved targeting and examination of high-risk cargo. While the extent
of cooperation across all of the 58 CSI seaports now operating is
difficult to quantify, our observations at 6 CSI seaports and our
review of select CSI team evaluations provide examples of how
collaboration can benefit the CSI program, and conversely, how the lack
thereof can hinder progress.[Footnote 18]
At all 6 CSI seaports we visited, CBP officers or host government
officials told us that the relationship between the CSI team and the
host government has been positive or has improved over time. CBP and
host government officials we spoke with at all of the seaports we
visited reported that establishing trust and collegiality has led to
increased information sharing, resulting in more effective targeting
and examination of high-risk container cargo. For example, CBP officers
noted instances in which host customs officials would occasionally
notify them of container cargo they thought could be high-risk, so that
CBP could take a closer look at the information available in ATS
related to the container cargo. In addition, a few CBP officers or host
government officials stated that the presence of CSI teams at foreign
seaports has in many instances helped to prevent unnecessary
examinations because information provided by host government customs
officials has led to lower risk profiles for certain container cargo.
Moreover, CBP officials reported that strengthened relationships with
host government officials and the trade community have led host
governments to bolster their customs and port security practices. CBP
officials we spoke to emphasized that, like the United States, most
foreign customs administrations have traditionally focused on revenue
collection and the seizure of contraband, rather than security
concerns. During our visits to CSI seaports, the CBP and host
government officials we spoke with reported several examples of how the
presence of CSI teams at seaports has helped to expand the focus of the
efforts of these foreign customs administrations and the trade
community to include enhanced security practices. For example, one
country developed databases with trade information to achieve its
customs goals and to assist CSI after seeing how gathering historical
data benefited CBP. Furthermore, at a couple of the CSI seaports we
visited, the CSI team or host government officials arranged outreach
meetings with the trade community to raise companies' awareness of
security practices and the benefits of providing correct and complete
data about their cargo.
During our visits to CSI seaports and our review of data CBP collected
during its evaluations of CSI teams, we also identified instances where
cooperation between CSI teams and their counterparts in the host
government could be improved--though, as CBP officials noted, some of
the factors involved are beyond CBP's ability to control directly. For
example, in some locations, CBP officials reported that a country may
have laws that hinder the collaboration of host government officials
with CSI teams. We identified the following issues during our
observations at 6 CSI seaports as well as from our review of CBP data
collected in fiscal year 2007 at an additional 12 CSI seaports (for a
total of 18 CSI seaports):
* At 9 CSI seaports, the CSI teams there reported that they only
interacted infrequently with their host government counterparts or the
host government officials did not readily share information that would
benefit CSI, such as knowledge about potentially suspicious container
cargo. In one instance the lack of interaction was attributed to the
host government's competing priorities.
* At 6 CSI seaports, host governments restricted CSI teams from viewing
nonintrusive inspection equipment examinations conducted by host
customs authorities or the resulting images of the container's
contents, which is one of the key purposes for staffing CBP officers at
CSI seaports.
* At 4 CSI seaports, host governments prohibited the use of hand-held
radiation detection devices by CBP officials, which is considered by
CBP to be an important way to identify a potential anomaly in a high-
risk container. According to CBP officials, a few of the countries
prohibit the equipment due to safety and health concerns about the use
of the equipment.
* At 3 of the CSI seaports, host customs officials lacked access to
technical equipment, such as computers or nonintrusive inspection
equipment that worked properly, which CBP believes could limit their
ability to share customs-related information with CSI team members or
efficiently conduct examinations. According to CBP officials, sometimes
host governments lack resources to meet these technological needs.
* At 6 CSI seaports in 2 countries, CBP officers at the seaport
reported that host customs administrations did not provide a sufficient
number of staff to assist CSI teams or the host government officials
were often unavailable, which, according to CSI teams, can sometimes
lead to delays in examining high-risk containers.
* At 3 CSI seaports, there was evidence of challenges to effective
communication, such as some CSI teams having limited proficiency in the
local language.[Footnote 19]
These examples are not intended to represent the CSI program as a
whole, but are included to illustrate the types of challenges that CSI
teams at the seaports and CBP program managers face. CBP officials
responsible for managing the CSI program have reported that overall
there has been a high level of cooperation at CSI seaports, though they
acknowledged that the degree of involvement and participation that CBP
officers have with foreign customs officials during the examination of
high-risk cargo varies by country. It is also important to note that
while CBP negotiates a written, nonbinding arrangement stating
expectations for inclusion in the CSI program with the participating
foreign governments, the agency cannot compel foreign governments to
offer information for the purposes of CSI or to examine high-risk
containers. Later in this report, we describe the processes CBP has in
place to address difficulties that may be identified at the CSI
seaports as part of its program oversight and monitoring efforts.
Seaport Environment and Logistics Present Challenges to CSI Operations:
Another factor that can affect CBP's ability to conduct CSI program
operations involves logistical challenges that are inherent to many
seaport environments. For example, as illustrated in figure 6, foreign
government officials we spoke with at CSI seaports reported that many
seaports are densely packed with equipment and personnel, which can
make it difficult for host government customs officials to examine
container cargo.
Figure 6: View of the Physical Layout of a Congested CSI Seaport:
[See PDF for image]
This figure is a photograph of the physical layout of a congested CSI
Seaport.
Source: GAO.
[End of figure]
According to CBP, open space to place scanning equipment or to conduct
physical searches of containers can be scarce at some CSI seaports. For
example, in two of the CSI locations we visited, scanning equipment and
examination sites were placed several miles from where container cargo
is unloaded, loaded, or stored. According to the CBP officials we spoke
with, this adds to the costs and time required for examination and may
result in logistical difficulties in having high-risk U.S.-bound
containers examined before being loaded onto the shipping vessel. In
addition, at one port we visited, the host government limited the
number of containers it would examine, in part to limit the cost of
examination and the amount of delay caused by moving these containers,
according to the CSI team we spoke with. CBP officials reported that
despite this limit to examine no more than 250 containers (out of the
over 115,000 container cargo shipments to the United States from this
seaport in fiscal year 2007), the country has not denied many
examination requests--only two in fiscal year 2007. However, this
ceiling was not based on risk factors, and an increase in denied
requests could lead to additional containers with high-risk cargo
departing for the United States without being examined.
Finally, CBP officials stated that containers at seaports are generally
stored in a container yard before they are loaded onto the shipping
vessel. These container yards may be very large, and containers in
these yards are often stacked to minimize the time required to load
container vessels. As shown in figure 7, containers on a vessel may be
stacked several layers deep. Accordingly, CBP and host government
officials we spoke to at a few CSI seaports reported it can sometimes
be challenging to access a container for examination. CBP officials
noted that any examinations requested but not conducted in the CSI
seaport would occur at a U.S. seaport upon arrival.
Figure 7: Stacked Containers on a Shipping Vessel at a CSI Seaport:
[See PDF for image]
This figure is a photograph of stacked containers on a shipping vessel
at a CSI Seaport.
Source: GAO.
[End of figure]
CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Performance
Measures but Still Does Not Capture Critical Information about Host
Government Examination Systems:
CBP has enhanced how it collects CSI data by strengthening its approach
to conducting periodic evaluations of CSI officers at CSI seaports
through on-site evaluations of performance. However, weaknesses remain
in how CBP conducts evaluations, the information collected regarding
host government examination systems, and performance measurement of the
program as a whole.[Footnote 20] For example, CBP does not
systematically collect information on the equipment, people, and
processes that are part of the host government's overall examination
system. Also, while CBP has refined and updated its performance
measures, we identified remaining limitations, such as the omission of
measures for all core program elements and several performance targets.
CBP Significantly Improved Its CSI Evaluations to Assess Program
Operations at CSI Seaports, but Weaknesses Remain:
CBP conducts evaluations at CSI seaports to determine the effectiveness
of the program. Specifically, CBP uses these on-site evaluations to
assess CSI team operations and capabilities, such as how well CSI team
members use ATS to determine the risk levels associated with U.S.-bound
containers passing through CSI seaports. CBP's CSI strategic plan
states that these periodic reviews are intended both to ensure that
deployed CSI teams are adhering to standard operating procedures as
well as to evaluate the relationships between the teams and the host
customs administrations. In fiscal years 2006 and 2007, CBP reported
conducting 42 and 45 evaluations, respectively. Since the program's
inception in 2002, the agency reported conducting a total of 202
evaluations.
In November 2006, CBP significantly changed the way it conducts CSI
team evaluations. Prior to that time, CBP officials reported that its
evaluators relied on self-reported information from CSI team members on
how proficiently they performed CSI program activities. CBP's current
approach to conducting CSI team evaluations seeks to provide a more
thorough review of CSI team performance. According to CBP officials,
the agency now requires the CSI team members under review to
demonstrate their targeting competence to an evaluator, such as by
physically showing the evaluator how they review information about
container cargo to determine its risk level. To better assess the
deployed CSI team's performance, CBP augmented its evaluation teams
with officers who have expertise in areas such as targeting and
intelligence gathering.
Also, CBP has developed a new software tool that enables evaluators to
record evaluation data electronically, using laptop computers to
conduct the on-site evaluations. This tool, CSI Team Evaluation
(CSITE), consists of a series of yes or no questions that cover the
various areas of CSI team performance, including whether all of the
container cargo that the CSI team designated high-risk were examined
and whether these actions were properly documented. The CSITE tool also
provides guidance on each question and prompts evaluators as they
conduct their review by, for example, directing them to ensure that the
CSI team is using the correct settings in ATS. In addition, employing
CSITE, CBP reported it can now aggregate the results of some or all of
its evaluations, a capability it previously lacked, and can conduct
statistical analyses of the results of the evaluations. The agency can
determine, for example, what percentage of CSI team members
successfully demonstrated proficiency in targeting high-risk
containers. According to CBP officials, CSITE will eventually allow the
agency to make comparisons of CSI performance across seaports.
Moreover, CBP now retains the information it collects at CSI seaports
and the resultant evaluation reports in a more systematic fashion. CBP
officials acknowledged that the agency did not always store this data
effectively prior to the implementation of the new evaluation system
and could not provide us with documentation of all of the evaluations
it had conducted since the program's inception.
While these efforts should help to strengthen the CSI team evaluation
process, CBP is still not consistently collecting all available data to
aid in its analysis of CSI team performance, and we identified
instances in which the agency did not reconcile contradictory
information it had collected. Based on our review of CBP's
documentation associated with 34 evaluations to assess the information
the agency collected and its methods for doing so, we found that
evaluators do not always answer all of the questions contained in
CSITE.[Footnote 21] For example, the software tool instructs the CBP
evaluation team to collect information on whether recommendations made
in prior evaluations have been implemented. This information could
allow CBP to determine whether past problems have been addressed, but
it is not always provided by the evaluation team. We also identified
discrepancies between (a) the CSITE checklist of questions that the
evaluation team completes during the onsite evaluation, and (b) the
resulting evaluation report produced by CBP headquarters officials for
2 of the 14 locations for which we had both documents to compare. At
one seaport, for example, the CBP evaluation team indicated in the
CSITE checklist that the CSI team did not have all of the data systems
it needed to effectively target outbound shipments, whereas the
evaluation report stated the team had access to all of the appropriate
targeting tools and databases. With more complete information,
collected in a consistent manner, CBP may be better able to determine
how well CSI teams are performing, what corrective actions may be
needed to improve the program, or whether the CSI program is achieving
its security goals.
CBP Lacks a Process for Systematically Gathering Information on Host
Government Examination Systems, Which Include Equipment, People, and
Processes:
Host Government Examination Systems--Equipment:
In April 2005, we recommended that CBP establish minimum technical
criteria required for the capabilities of nonintrusive inspection
equipment at CSI seaports, while considering sovereignty issues with
participating countries. CBP agreed to evaluate the feasibility of
establishing such criteria. In 2006, section 205(e) of the SAFE Port
Act required DHS to establish minimum technical capability criteria for
the use of nonintrusive inspection equipment and nuclear and
radiological detection systems in conjunction with CSI, but noted that
these criteria should not be designed to conflict with the sovereignty
of host countries. In 2007, the 9/11 Act also required the Secretary of
DHS to develop technological standards for scanning systems that will
be used to conduct 100 percent scanning at foreign seaports in the
future and to ensure that these and other actions implementing the
act's 100 percent scanning provisions do not violate international
trade obligations and are consistent with the World Customs
Organization framework or other international obligations of the United
States. [Footnote 22] CSI host governments, which are responsible for
conducting examinations of container cargo, purchase and operate
nonintrusive inspection equipment, though as of November 2007, 13 CSI
seaports use equipment on loan from the United States. The capabilities
of this inspection equipment vary by manufacturer and model. The
equipment may differ, for example, in its ability to penetrate steel
shielding in order to generate an image of container contents, or may
scan containers at different rates. Appendix IV describes the
capabilities of this equipment in greater detail. As of November 2007,
CBP had not yet implemented our prior recommendation or taken actions
to meet the SAFE Port and 9/11 Acts requirements for setting minimum
technical criteria. CBP officials stated that the reason for this is
that they do not consider the agency to be a standard-setting
organization. While CBP refers host governments to the World Customs
Organization' SAFE Framework regarding the procurement of inspection
equipment, this document does not include specific technical criteria
or standards. Moreover, they added that it is important to acknowledge
the inherent challenges involved in efforts to ascertain the
capabilities of nonintrusive inspection equipment that is owned and
operated by CSI host governments.
In May 2005, however, CBP put forth minimum technical criteria to
evaluate the quality and performance of nonintrusive imaging inspection
equipment being considered for use at U.S. seaports.[Footnote 23] These
domestic standards set baseline performance requirements for
penetration, contrast sensitivity, throughput, image quality, and scan
size. To determine whether certain types of nonintrusive inspection
equipment were acceptable for use at domestic seaports--and could meet
the criteria that had been set--CBP conducted tests comparing the
capabilities of nonintrusive imaging inspection equipment provided by
seven manufacturers with its technical operating standards. On the
basis of the test results, CBP recommended the inspection equipment
from five of the seven manufacturers for use at domestic seaports,
while equipment from two manufacturers was not recommended. CBP
officials stated that there are no plans to systematically compare the
capabilities of inspection equipment at CSI seaports against these
criteria for domestic equipment due to sovereignty concerns.
CBP collects limited information on certain characteristics of the
inspection equipment installed at CSI seaports, such as manufacturer;
however, information related to capabilities and performance is not
generally obtained. Officials in CBP's Office of Technology stated that
they have information on the capabilities of equipment that the United
States loans to other countries for 16 CSI seaports, and that only this
equipment can be assured of meeting the CBP domestic requirements.
However, these CBP officials said that they had neither determined
which other CSI seaports use the inspection equipment that was assessed
as part of CBP's test and recommended for use at domestic seaports, nor
systematically determined the specific capabilities of the equipment
used at those CSI seaports. Host government officials in the countries
we visited stated that they followed their country's acquisition
procedures, which included reviewing equipment capabilities and
performance, among other things, for the purchase of nonintrusive
imaging inspection equipment. However, CBP does not have documentation
on the testing used by the host countries or the manufacturers to
determine the basis for the equipment's stated performance or whether
this stated performance is less than, meets, or exceeds the criteria
CBP established for equipment used at domestic seaports.
According to CBP officials, the capabilities of nonintrusive inspection
equipment are vetted during an assessment phase of the CSI program,
when CBP is determining whether a seaport is prepared to operate within
CSI. While, as part of the assessment phase, CSI officials stated that
they collect descriptive technical information about the type of
nonintrusive inspection equipment to be used at seaports, we did not
find--in our review of CBP's checklist used to guide its assessment
teams as they examine prospective CSI seaports--questions covering
inspection equipment other than general direction to ascertain whether
some type of this equipment was in place. Also, through our review of
CBP's assessments of 10 CSI seaports--through which approximately 55
percent of all U.S.-bound containers passed in fiscal year 2007--we did
not find any assessments that described the performance capabilities of
the equipment or judgments about the proficiency of host government
officials in operating these systems. CBP officials stated that the
agency has never prohibited a seaport from participating in CSI on the
basis of its inspection equipment, and CBP documents show that
participation in the program requires only that some type of
nonintrusive inspection equipment be available at or near the potential
CSI port.
Host Government Examination Systems--People and Processes:
The SAFE Port Act also directed DHS to (1) establish standard operating
procedures for the use of nonintrusive inspection equipment at CSI
seaports and (2) require CSI seaports to operate the equipment in
accordance with the criteria and operating procedures established by
DHS.[Footnote 24] Also, the 9/11 Act required DHS to develop
operational standards for scanning systems that will be used to conduct
100 percent scanning at foreign seaports in the future. CBP officials
stated that they recognize that the capabilities of nonintrusive
inspection equipment are only one element for determining the
effectiveness of examinations that take place at CSI seaports. It is
better, in their view, to make assessments of the whole examination
system, which includes nonintrusive inspection equipment, personnel,
and processes.However, CBP acknowledged it does not systematically
collect information on host governments' use of examination systems and
has not developed general guidelines or criteria that could provide CBP
with the means to determine the quality of examinations of high-risk
container cargo bound for the United States. CBP officials stated that
they rely on CSI teams to notify headquarters if they have concerns
about the host government customs or examination practices.
Specifically, each CSI team leader is to meet weekly--usually via
teleconference--with a CSI manager located at CBP headquarters to
discuss ongoing CSI operations. However, CBP officials acknowledged
that equipment, capabilities, and examinations practices of host
government customs personnel are not routinely discussed.
CBP officials also reported that CSI team members witness most
examinations of high-risk U.S.-bound containers, and their presence at
the examinations would allow them to make judgments about aspects of
the host government's examination system. However some host governments
specifically prohibit CSI team members from witnessing examinations.
Also we found that CBP officials did not routinely observe inspections
at one CSI seaport we visited, and were not always able to be present
for inspections at two other CSI seaports because those inspections
were scheduled and conducted when CBP officials were not available.
CBP officials told us that their CSI team evaluations are also a means
of capturing some information on various aspects of the host
government's examination system. In order to participate in CSI, CBP
requires that, among other things, host governments have customs staff
capable of examining cargo originating in or transiting through its
country and maintain a program to prevent breaches in employee
integrity. However, the 15 CSI team evaluations we reviewed, which CBP
had conducted since the agency revised its evaluation process in
November 2006, showed limited coverage of whether host government
customs personnel have been trained to use nonintrusive inspection
equipment or are using it properly, the sufficiency of host staffing
levels, and host government efforts to ensure the integrity of their
customs administration. Specifically, 6 of the 15 CSI team evaluations
discussed whether equipment was used properly, 1 discussed host
staffing levels, and none discussed host integrity programs.
CBP's Lack of Information on Host Government Examination Systems
Potentially Limits Assurance That Examinations of High-Risk Container
Cargo are Effective:
CBP's lack of a systematic way to collect information on host
governments' examination systems--including their equipment, people,
and processes--potentially limits CBP's ability to ensure that
examinations of high-risk container cargo at CSI seaports can detect
and identify WMD. Without information on host governments' examination
systems, CBP management may not be able to determine the reliability of
the host government's inspections of high-risk U.S.-bound container
cargo. This is of particular concern since, according to CBP officials,
most high-risk cargo that has already been examined at a CSI seaport,
is generally not reexamined once it arrives at a U.S. seaport.[Footnote
25] CBP officials stated that if problems are found in the examination
process at a CSI seaport, then high-risk container cargo would be
reexamined upon arrival in the United States.
As already noted, CBP must respect participating countries'
sovereignty. CBP cannot require that a country use specific equipment.
However, if a high-risk container was examined using an examination
system found by CBP to be less capable than established criteria, the
agency could require that the container be reexamined upon arrival at a
U.S. seaport. CBP officials stated that they believe that in general
the equipment used by participating governments meets or exceeds the
capabilities of the nonintrusive inspection equipment used at U.S.
seaports. However, because CBP has not set minimum technical criteria
for nonintrusive inspection equipment at CSI seaports, and the agency
does not systematically review the operations of the host government
examination systems at CSI seaports, CBP potentially has limited
assurance that their inspection equipment is capable of detecting and
identifying potential WMDs. In light of the new 9/11 Act requirement
that 100 percent of U.S.-bound container cargo be scanned in the future
with nonintrusive inspection equipment at foreign seaports before
leaving for the United States, it is important that CBP have processes
in place to gather the information necessary to ensure that cargo
container examinations--and the equipment used as part of the
examination process--are reliable, regardless of the point of origin.
CBP Made Efforts to Refine CSI Performance Measures, but Did Not Fully
Address our Previous Recommendation:
While CBP has taken steps to strengthen performance measures for the
CSI program, we identified areas that did not fully address our April
2005 recommendation to develop outcome-based performance measures or
proxy measures of program functions--if program outcomes could not be
captured--and performance targets to track the program's progress in
meeting its objectives. Whereas CBP's CSI team evaluations and program
monitoring activities help to evaluate CSI operations at the seaport
level, CBP uses performance measures to gauge the effectiveness of the
overall program in meeting its broader strategic objectives for CSI
across seaports. By definition, performance measures are a particular
value or characteristic used to quantify a program's outputs--which
describe the products and services delivered over a period of time--or
outcomes--which describe the intended result of carrying out the
program. A performance target is a quantifiable characteristic that
establishes a goal for each measure; agencies can determine the
program's progress, in part, by comparing the program's measures
against the targets. For example, the target of one of CBP's
performance measures--the "number of operational CSI seaports"--was to
have 58 CSI seaports operating in fiscal year 2007, which the agency
achieved as described previously in this report. The Government
Performance and Results Act of 1993 incorporated performance
measurement as one of its most important features, and the
establishment and review of performance measures are a key element of
the standards for internal control within the federal
government.[Footnote 26] As discussed in the Government Performance and
Results Act of 1993 and as we reported in 1996, measuring performance
allows organizations to track progress being made toward specific goals
and provides managers crucial information upon which to base their
organizational and management decisions.[Footnote 27] In addition,
leading organizations recognize that performance measures can create
powerful incentives to influence organizational and individual behavior.
In the past 2 years, CBP has made efforts to refine and modify its
performance measures as the CSI program has matured. Since 2005, for
example, CBP has eliminated five performance measures that it had used
to track the implementation of seaports participating in CSI, measures
that CBP determined were no longer needed because CSI operations were
under way at the majority of planned CSI seaports. Also, in our April
2005 review of CSI, we identified a CSI performance measure that was
calculated inappropriately, and in response, CBP modified how the
measure was calculated to address our concerns. Specifically, for the
CSI measure that tracks the number of container examinations waived
because they are determined to be unnecessary, CBP began excluding
inappropriate data that made the results of the performance measure
misleading.[Footnote 28] This was an important modification because, as
we reported in November 2002, measures that are defined inconsistently
with how they are calculated can be confusing and create the impression
that performance is better or worse than it actually is.[Footnote 29]
CBP has made efforts to enhance CSI performance measures, but we
identified limitations in the information available for CSI program
managers to assess the program. In the past, we and the Office of
Management and Budget have encouraged federal departments and agencies
to measure whether programs are achieving their intended outcomes, such
as CSI's purpose of protecting global trade from being exploited by
international terrorists. However, we and the Office of Management and
Budget have acknowledged the difficulty in developing outcome measures
for programs that aim to deter or prevent specific behaviors. In such
an instance, we have reported that proxy measures should be designed to
assess the effectiveness of program functions. CBP officials reported
the agency has not been able to develop a way to measure the deterrence
effect of the program, as CSI is designed to support the CBP mission to
prevent and deter terrorists and terrorist weapons from entering the
United States. Examples of CSI program functions include targeting and
examining high-risk container shipments before they are loaded on
vessels bound for the United States, and in our 2005 review of CSI we
provided guidance on an alternative method of developing proxy measures
to evaluate program performance. Further, according to the Office of
Management and Budget, proxy measures should be closely tied to the
intended program outcome, and it may be necessary to have a number of
proxy measures to help ensure sufficient safeguards are in place to
account for performance results. According to CBP officials the
following three of its existing performance measures were proxies for
program outcomes.[Footnote 30]
(1) The percentage of worldwide U.S.-bound containers passing through
CSI seaports--since these containers are to be targeted and, if
determined high-risk, may be examined by host government officials,
this is a measure of the program goal to detect and prevent WMDs headed
to U.S. seaports from leaving foreign seaports.
(2) The number of foreign mitigated examinations (that is, examinations
determined to be unnecessary due to information provided by host
government officials and thus waived) by category--developed to
quantify whether collocating CBP officials at CSI seaports increases
information sharing and collaboration.
(3) The number of intelligence reports based on CSI foreign sources--
intended to measure whether having CBP officials located at foreign
seaports leads to increased collaboration with foreign customs
officials.
The Office of Management and Budget has stated that performance
measures should capture the most important aspects of a program's
mission and priorities. However, CBP does not have a measure that
tracks the extent to which U.S.-bound containers carrying high-risk
cargo are examined at CSI seaports, despite the fact that this activity
is a core element of the CSI program.
CBP has taken other actions to address our April 2005 recommendation
that includes ways to improve CSI performance measures, but we found
additional weaknesses as well. The strategic plan demonstrated how each
performance measure corresponds to the three strategic goals of CSI,
which include (1) securing U.S. borders, (2) building a robust CSI
cargo security system, and (3) protecting and facilitating trade. This
marked an improvement, as this linkage had not been made previously. In
addition, CBP addressed an additional aspect of our prior
recommendation by establishing performance targets for four of the six
CSI performance measures currently used. However, only one measure had
a target for multiple years. In addition, since issuing the CSI
strategic plan the agency has not updated its performance targets for
fiscal year 2008 or beyond for any of its measures. Without this
information about the performance targets, it may be difficult for CBP
to determine whether the results were more positive or negative than
expected.
Also, we identified a weakness in how some CSI performance measures are
calculated. As we noted earlier in this report, as the number of CSI
seaports has increased in recent years, program activities have
increased as well. However, CBP does not appropriately control for this
program growth in how it calculates three of its six performance
measures. For example, since the "number of foreign mitigated
examinations by category"--the number of container examinations
determined to be unnecessary due to information provided by host
government officials--is not calculated on a per-container basis (i.e.,
per 10,000 containers), it may be difficult to determine whether
fluctuation in the numbers across years is due to (1) increased
collaboration with foreign government officials or (2) simply an
increase in the number of containers reviewed and considered for
examination at the increasing number of CSI seaports. Similarly, the
number of intelligence reports and the number of investigative cases
initiated may be due to an increase in the number of operational CSI
seaports, not increased collaboration with host government officials.
Without controlling for program growth, CBP's calculation of results
for its performance measures may be misleading or confusing to CBP and
DHS program managers or the Congress, who provide program oversight.
Conclusions:
Since we began reporting on the CSI program in 2003, CBP has made
significant progress in expanding and developing the program. However,
CBP continues to face several management and operational challenges,
which may limit CBP's ability to ensure that the CSI program provides
the intended level of security for U.S.-bound container cargo moving
through the international supply chain. Also, balancing security
concerns with the need to facilitate the free flow of commerce remains
an ongoing challenge for CBP.
Recognizing that program evaluation data are important for program
managers to understand why results occur and what value a program adds,
CBP has taken actions to enhance its evaluation of CSI team activities.
The revised evaluation program has increased the information available
to make policy and programmatic decisions regarding the operations at
the CSI seaports. However, limitations that remain in CBP's evaluation
process affect the accuracy and completeness of the program information
available for making sound management decisions about the CSI program
as a whole. Specifically, when CBP's evaluation teams do not complete
the evaluation tools or resolve contradictory information, program
managers may receive limited or inaccurate information. Further, when
the data collected using the CSI evaluation tool during the evaluations
are not reliable and readily available for assessment, CBP's planned
programwide trend analyses of the CSI program may be misleading.
In assessing CSI performance, CBP lacks information about a very
important aspect of the program--the overall examination systems used
by the host governments to examine high-risk cargo shipped in
containers as requested by CBP. CBP's efforts have led to the
successful participation of a wide array of foreign governments in the
CSI program, and CBP has established many cooperative relationships
with its foreign partners. While we acknowledge the agency cannot force
security requirements upon foreign governments, the lack of information
systematically gathered about the examination systems used by
participating governments is problematic. Data about the equipment,
people and processes involved in the examination system are vital for
determining whether high-risk U.S.-bound containers have been properly
examined or should be examined or reexamined upon arrival at a U.S.
seaport. CBP lacks guidelines and criteria for most of the equipment
and the people and processes used by host government examination
systems--as required, in some instances, by the SAFE Port and 9/11
Acts--for evaluating CSI seaport operations and determining overall
program effectiveness. In light of the new 9/11 Act requirement that
100 percent of U.S.-bound container cargo be scanned in the future at
foreign seaports before leaving for the United States, it is important
that that CBP have programs in place to gather the information
necessary to ensure that cargo container examinations--and the
equipment used as part of the examination process--are reliable,
regardless of the point of origin.
Program evaluations are just one source of information that managers
need to make decisions, and evaluation data must often be coupled with
performance measurement to assess overall program results. Measuring
the overall impact of the CSI program remains difficult due to the
challenges involved in creating effective performance measures, and
because of great difficulty in measuring the deterrent effect of the
program. As we and the Office of Management and Budget have reported,
performance measurement can be very valuable to program managers, as
the process can indicate what a program is accomplishing and whether
intended results are being achieved. Measuring program performance
encourages managers to focus on the key goals of a program and helps
them by providing information on how resources and efforts are best
allocated to ensure effectiveness. Though CBP identified performance
measures it considers proxies for program outcomes (given the
difficulty in assessing the deterrent effect of CSI), these measures do
not cover a key core program function, for example a performance
measure for the number of high-risk U.S.-bound containers examined at
CSI seaports. Finally, without clearly developed performance targets
for each of its measures, program managers, Congress, and the public
lack information needed to determine the extent to which the CSI
program is performing as intended. Taken as a whole, the lack of
clearly articulated performance measures and accurate and reliable
evaluative data may hinder CBP's ability to ensure that the resources
it expends for CSI effectively achieve its goal of helping to secure
U.S. borders against terrorists and terrorist weapons.
Recommendations for Executive Action:
To help ensure that CBP has the information needed to assess its
achievement of CSI program goals to help enhance supply chain security-
-while at the same time balancing security concerns with the need to
facilitate the free flow of commerce--we recommend that the Secretary
of Homeland Security direct the Commissioner of U. S. Customs and
Border Protection to take the following actions in three areas:
* Strengthen CBP's process for evaluating CSI teams at overseas ports
by (a) systematically capturing and maintaining all relevant evaluation
data and documentation so that it can be used by CBP management to
guide operating decisions, monitor program performance, and inform
resource allocation decisions; (b) ensuring that CSI evaluation teams
follow established evaluation procedures; and (c) monitoring the
completion, within established time frames, of recommendations made in
previous evaluations.
* In collaboration with host government officials, improve the
information gathered about the host governments' examination systems--
which includes people, processes, and equipment--at each CSI port by
(a) establishing general guidelines and technical criteria regarding
the minimal capability and operating procedures for an examination
system that can provide CBP with a basis for determining the
reliability of examinations and related CSI activities; (b)
systematically collecting data for that purpose; and (c) analyzing the
data against the guidelines and technical criteria to determine what,
if any, mitigating actions or incentives CBP should take to help ensure
the desired level of security.
* Enhance CSI performance measures to better assess CSI performance
overall by (a) developing measures for all core CSI program functions
designed to have a deterrent effect, (b) establishing annual
performance targets--based on explicit assumptions--for all performance
measures, and (c) revising how performance measures are calculated to
take into account CSI program growth.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Department of State and the
Department of Homeland Security for their review and comment. The
Department of State did not provide written comments but provided
technical comments, which have been incorporated into the report as
appropriate. DHS provided written comments--incorporating comments from
CBP--on December 20, 2007, which are presented in Appendix II. In
commenting on a draft of this report, DHS noted that it concurred with
one recommendation and partially concurred with the remaining two
recommendations.
In its written comments, DHS and CBP concurred with our recommendation
on strengthening its process for evaluating CSI teams at overseas
locations. Specifically, CBP noted that by June 2008, it planned to
establish a database that would contain all recommendations and action
plans as a result of CSI port evaluations as well as due dates for
implementing recommendations and actions taken. To ensure that CSI
evaluation teams follow procedures, CBP indicated that it would make it
mandatory that the teams complete all database fields. Furthermore, CBP
reported that it would assign values to questions in its evaluation
tool on the basis of the criticality of the activity evaluated in each
question to CSI's mission as a whole.
DHS commented that CBP partially concurred with our second
recommendation to improve information gathered about host governments'
examination systems by (a) establishing general guidelines and
technical criteria regarding the minimal capability and operating
procedures; (b) systematically collecting data for that purpose; and
(c) analyzing the data against the guidelines and technical criteria.
CBP agreed on the importance of an accepted examination process and
noted it continues to take steps in addressing improvements in the
information gathered about host government's examination systems at CSI
seaports by working directly with host government counterparts, through
the World Customs Organization, and providing capacity building
training and technical assistance. While CBP does engage in capacity
building, it does so with only 5 of the 33 countries with CSI ports.
CBP also stated that it will continue to use the WCO through its SAFE
Framework of Standards to address a uniform customs process and
technical standards for equipment. However, the SAFE Framework mentions
no specific technical capability criteria for inspection equipment.
Additionally, CBP does not systematically collect or assess information
on the people, processes, or technology used by these host governments
to examine high-risk U.S.-bound containers. CBP also noted in its
comments to this report, that equipment used for inspection of
containers in foreign countries is equal to or better than the
equipment used by CBP at its domestic ports. While CBP has performance
information for the 16 seaports that have inspection equipment on loan
from CBP, it is not in a position to assess the performance of
equipment used at the remaining 42 CSI seaports. Although we repeatedly
requested systematic information regarding the equipment technical
capabilities in these other ports, CBP officials were unable to provide
it to us. In response to our 2005 report, CBP stated that it would
evaluate the feasibility of technical requirements for nonintrusive
inspection equipment, but a legal issue may exist regarding CBP's
ability to impose such requirements. While we understand CBP's
position, it could still gather information on such equipment's
technical capabilities. Because the CSI inspection might be the only
inspection of a container before it enters the United States, it is
important that information on the people, processes, and equipment used
as part of CSI be obtained and assessed to provide some level of
assurance of the likelihood that the examination system could detect
the presence of WMD. If a port's examination system were determined to
be insufficient, CBP could take mitigating actions, such as re-
examining container cargo upon its arrival at a domestic seaport.
Finally, DHS commented that CBP partially concurred with our third
recommendation to enhance CSI performance measures to better assess CSI
performance overall. CBP stated that it believes its current measures
address core program functions of targeting and collaboration with host
governments to mitigate or substantiate the risk of a maritime
container destined for the United States. We disagree. As discussed
earlier in this report, a core element of the CSI program, specifically
the extent to which U.S.-bound containers carrying high-risk cargo are
examined at CSI seaports, is not addressed through CBP's performance
measures. In its comments, CBP stated that its outcome performance
indicator captures the number of foreign mitigated examinations by
category, however CBP did not respond to our requests for more
information regarding these categories, including whether risk was a
category. Although it considers action on this recommendation
completed, CBP noted its intention to continue to refine, evaluate, and
implement measures to track progress toward meeting CSI objectives. As
previously stated, since issuing the CSI strategic plan, CBP has not
updated its performance targets for fiscal year 2008 or beyond for any
of its measures. Thus, we believe additional action is warranted.
Establishing annual targets for performance measures is important, as
agencies can determine the program's progress, in part, by comparing
the performance measures against the targets. In addition, CBP did not
address whether it plans to reconsider how it calculates some of its
performance measures to control for CSI program growth. Without doing
so, CBP's calculation of results for its performance measures may be
misleading or confusing to CBP and DHS program managers, or the
Congress, who provide program oversight.
DHS and CBP also provided technical comments, which have been
incorporated into the report as appropriate.
If you or your staff have any questions about this report, please
contact me at (202) 512-9610 or at caldwells@gao.gov. Key contributors
to this report are listed in appendix VI. This report will also be
available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
Signed by:
Stephen L. Caldwell:
Director, Homeland Security and Justice Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Objectives:
We addressed the following issues regarding the U.S. Customs and Border
Protection's (CBP) Container Security Initiative (CSI):
* How has CBP contributed to strategic planning for supply chain
security efforts and the CSI program in particular, and what progress
has been made in achieving CSI performance goals?
* How has CBP strengthened CSI operations in response to our 2005
review, and what challenges, if any, remain?
* How does CBP evaluate CSI port operations and assess program
performance overall, and how has this process changed over time?
Scope and Methodology:
To address our first objective, we reviewed the strategic plans of the
Department of Homeland Security (DHS), CBP, and CSI as well as national
strategies like the National Maritime Security Strategy and the
Strategy to Enhance International Supply Chain Security. We also
analyzed the CSI strategic plan to determine whether it includes all of
the key elements included in the Government Performance and Results
Act. In addition, to measure CSI's progress in meeting its performance
goals, we reviewed and analyzed CBP data related to the number of CSI
seaports, the cargo CBP targeted and referred to the host government to
examine, and the number of cargo containers that were (and were not)
examined by host government officials at the CSI seaports. We also met
with CBP officials responsible for managing the CSI program, from the
CSI Strategic Planning and Evaluation Branch, and from CBP's Office of
Field Operations and Office of International Affairs and Trade
Relations, not only to gather information about CSI strategic planning
and performance goals, but to discuss all of the issues within the
scope of this review.
To examine CBP's efforts to enhance CSI operations and the operational
challenges that remain at CSI seaports, we reviewed GAO's previous
assessments of the CSI program and examined CBP's efforts to implement
our three prior recommendations. We also reviewed the CSI human capital
plan and spoke to CBP officials about actions the agency has taken to
ensure that CSI human resources are appropriately allocated. As part of
that process, we met with officials at CBP headquarters and at the
National Targeting Center - Cargo (NTCC) in Virginia to discuss the
agency's decision to conduct some targeting of high-risk containers
from the NTCC rather than at CSI seaports.[Footnote 31] In addition, we
spoke to CBP officials at three domestic seaports, selected according
to geographical location and container volume. We also visited six CSI
seaports located overseas, and selected the locations based on
geographic and strategic significance, container volume to the United
States from the seaports, when the seaports began conducting CSI
operations, and whether the seaport was involved in CBP's Secure
Freight Initiative. At the CSI seaports, we also interviewed host
government officials and CSI teams to discuss the frequency and level
of collaboration involved in their interactions with each other,
circumstances at seaport facilities that affect CSI operations, and
financial cost issues associated with examinations. The results from
our visits to seaports provided examples of CBP and host government
operations but cannot be generalized beyond the seaports visited
because we did not use statistical sampling techniques in selecting the
seaports.
To determine what progress CBP has made in strengthening its tools for
monitoring and measuring the progress of the CSI program, we reviewed
the performance measures presented in the CSI strategic plan against
criteria developed by the Office of Management and Budget and GAO. In
addition, to appraise CBP's efforts to strengthen its methods to
evaluate CSI teams and to learn about operations at CSI seaports, we
analyzed a sample of evaluation documents. Our nonrepresentative sample
consisted of evaluations for all 40 seaports for which we had
documentation at the time of our review, including (1) the 15
evaluations conducted between November 2006 (when CBP revised its
evaluation process and began using the Container Security Initiative
Team Evaluation software tool) and May 2007 (when we conducted our
analysis), (2) the 7 available evaluations that directly preceded them
chronologically and were conducted using CBP's previous evaluation
methodology (for the purpose of comparison), and (3) the most recent
evaluations conducted at each of the additional locations for which
documentation had been provided by CBP. Thus, we reviewed a total of 34
evaluations (covering 40 CSI seaports) out of the 114 evaluations that
GAO had obtained from CBP as of May 2007. For each of the evaluations
reviewed, we assessed any available materials, which could include a
narrative report and/or a checklist of yes or no responses. While our
sample covered various aspects of CBP's evaluations, our sample was not
selected using statistical sampling techniques. Thus, the results from
our review of CBP evaluation data provide illustrative examples about
CSI team evaluation methods and program operations at CSI seaports--and
generally corroborated our seaport site visit observations--but cannot
be generalized to the all 58 seaports conducting CSI operations.
We also met with CBP officials managing the CSI program to assess the
agency's efforts to collect information about the equipment, people,
and processes involved in the host governments' examinations of U.S.-
bound container cargo, including the capabilities of examination
equipment operating at CSI seaports and the proficiency of host customs
administrations using the equipment. In addition, we selected and
analyzed a nonrepresentative sample of 10 port assessments among those
that CBP conducted at each port prior to its admission into the CSI
program--the sample was composed of the 6 seaports we visited plus the
4 highest-volume locations as of January 2007. As of that date,
approximately 55 percent of containers bound for the United States
passed through these 10 seaports. Thus, our findings from our review of
the assessments provide examples about the type of information
collected as part of the process, but cannot be generalized to all 58
seaports in the program.
We conducted this performance audit from May 2006 through January 2008
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Data Reliability:
We met with CBP officials to discuss the agency's efforts to ensure CSI
data on the number of cargo shipments and containers subject to
targeting and examination are reliable. In our 2005 review of the
program, we found the data to be sufficiently reliable to support our
findings. Since that time, CBP has further enhanced the way in which it
collects and aggregates information about CSI program activities at
foreign seaports, including the targeting and examination of high-risk
container cargo. Specifically, CSI teams now utilize improved
technology, eliminating the need for transmitting data to CBP
headquarters via e-mail and thereby reducing the opportunity for human
error in manually entering and aggregating data for the program. CBP
officials at headquarters can now directly access the data entered at
each CSI port as soon as they are entered into the shared system and
can monitor the data on a daily basis to identify errors in or
mischaracterization of the data. While we did not directly test the
reliability of 2006 data, the recent CBP initiatives to improve
reliability, combined with GAO's previous assessment of the 2005 data,
gave us confidence in using CSI targeting and examination data to
provide descriptive, background information regarding the extent to
which high-risk container cargo is targeted by CBP and examined by
foreign governments participating in CSI.
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 205211:
[hyperlink, http://www.dhs.gov]:
December 20, 2007:
Mr. Stephen L. Caldwell:
Director, Homeland Security and Justice Issues:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Caldwell:
Thank you for providing us with a copy of the draft report entitled
"Supply Chain Security: Examinations of High-Risk Cargo at Foreign
Seaports have Increased, but Improved Data Collection and Performance
Measures are Needed" (GAO-08-187SU), which examines U.S. Customs and
Border Protection's (CBP) Container Security Initiative (CSI) program
and how CBP has contributed to strategic planning for supply chain
security, strengthened CSI operations, and evaluated CSI operations and
overall performance.
The Department of Homeland Security (DHS) and CBP agrees with the GAO's
overall observations and recommendation that CBP needs to enhance the
data collected about CSI team performance. CBP is concurring in part
with the recommendations made by GAO concerning host government
examinations and the further development of
performance measures and annual targets for core CSI functions as CBP
believes it has addressed and will continue to work on these areas as
deemed necessary. The following represents the Department and CBP
response to the recommendations included in the report.
Recommendation 1: Strengthen CBP's process for evaluating CSI teams at
overseas ports by (a) systematically capturing and maintaining all
relevant evaluation data and documentation so that it can be used by
CBP management to guide operating decisions, monitor program
performance, and inform resource allocation decisions; (b) ensuring
that CSI evaluation teams follow established evaluation procedures; and
(c) monitoring the completion, within established time frames, of
recommendations made in previous evaluations.
Response: CBP concurs with the recommendation and will enhance the
Container Security Initiative Team Evaluation (CSITE) by establishing a
data base that will contain all recommendations and action plans as a
result of a CSI port evaluation. The data base will include due dates
for each recommendation and annotate the appropriate action taken and
the results. In addition, the data base will be linked to CSITE in
order for the evaluator to have a record of previous recommendations
and actions taken for reference when conducting additional evaluations
or follow-up.
To ensure that CSI evaluation teams follow established procedures, it
will become mandatory that all data base fields are properly completed
in CSITE. This enhancement will address GAO's concern that not all
questions in CSITE had a response.
Moreover, CBP will establish a numerical "weight/value" for the
questions in CSITE. Numerical "weight/value" will be set for each
question and that numerical value will correspond to how critical a
negative response would affect the CSI mission as a whole. With these
numerical "weight/value", CBP will be able to provide an instant
"Report Card" on the CSI port being evaluated.
Due Date: June 30, 2008
Recommendation 2: In collaboration with host government officials,
improve the information gathered about host governments' examination
systems – which includes people, process, and equipment – at each CSI
port by (a) establishing general guidelines and technical criteria
regarding the minimal capability and operating procedures for an
examination system that can provide CBP with a basis for determining
the reliability of examinations and related CSI activities; (b)
systematically collecting data for that purpose; and (c) analyzing the
data against the guidelines and technical criteria to determine what,
if any, mitigating actions or incentives CBP should take to help ensure
the desired level of security.
Response: CBP agrees in part with this recommendation on the importance
of an accepted examination process and continues to take steps in
addressing improvements in the information gathered about host
governments' examination systems at CSI ports by working directly with
host government counterparts, through the World Customs Organization
(WCO), capacity building training and technical assistance.
CBP understands GAO's position in trying to determine the effectiveness
of the foreign customs service conducting examinations of high-risk
maritime containers destined for the United States. CSI has been in
operation for over five years and its success is attributed to the
cooperation and collaboration of our host government counterparts
examining high-risk containers that are referred for inspection.
Through the CSI program, CBP Officers work with host customs
administrations to establish security criteria for identifying high-
risk containers. With the establishment of security criteria, CBP has
benefited in identifying high-risk containers that pose a risk for
terrorism. Prior to CSI, many of these customs administrations were not
using non-intrusive (NII) technology to inspect the high-risk
containers before they are shipped to U.S. ports. Since the inception
of the CSI program, 58 CSI operational ports host government
administrations have invested millions of dollars on NII equipment that
includes their purchase of radiation detection devices such as
Radiation Portal Monitors for use in their examination process. The
level of examinations conducted at CSI locations increased by 93% from
70,902 in FY2006 to 136,815 in the FY2007. For the same time periods,
the percentage of cargo examined to overall CSI related shipments
increased by over 50% from 0.80% to 1.25%. These increased levels of
workload resulted in an array of enforcement actions and investigative
cases. This level of success could not have been accomplished without
the host government continued cooperation and having an effective
examination process.
Furthermore, host government officials have not hesitated in providing
CBP with all the information on equipment used for the inspection of
containers. This equipment is equal to or better than the equipment
used by CBP at its domestic ports. CBP Officers are fully trained in
the equipment being used by the host government, and in the cases where
CBP has provided NII equipment, those host government customs officials
also have been trained in the use of such equipment.
In addition to working directly with host governments, CBP provides
training and technical assistance to customs administrations of a
number of countries that currently participate in CSI. Such training
and technical assistance forms a long-term capacity building program to
support implementation of the WCO Framework of Standards to Secure and
Facilitate Global Trade. The standards incorporated in the Framework
contain key elements which support CSI including:
* Advance electronic presentation of cargo information;
* Screening of cargo containers using non-intrusive inspection
equipment;
* Use of automated risk management systems;
* Standardization of targeting criteria to identify high-risk cargo and
containers;
* Employee integrity programs; and;
* Inspection of cargo in the country of origin, transit and
destination.
CBP also provides a number of assistance and training programs to
foreign customs and border security agencies to facilitate
implementation of port security antiterrorism measures.
As a nation's sovereignty is critical, CBP will continue to use the WCO
through its Safe Framework of Standards, to address a uniform customs
process and technical standards for equipment to ensure that the
examination process of cargo is one that is uniform throughout the
world.
Recommendation 3: Enhance CSI performance measures to better assess CSI
performance overall by (a) developing measures for all core CSI program
functions designed to have a deterrent effect, (b) establishing annual
performance targets ” based on explicit assumptions ” for all
performance measures, and (c) revising how performance measures are
calculated to take into account CSI program growth.
Response: CBP concurs in part with the recommendation. CBP believes
that its current measures do address and assess CSI core program
functions of targeting and collaboration with the host government in
order to mitigate or substantiate the risk of a maritime container
destined to the United States.
CBP will continue to refine, evaluate and implement any and all
performance measures needed to track the progress in meeting any
additional CSI objectives.
CBP's current performance measures include two outcome, four
information and one efficiency measures. These performance measures
have been accepted by the Office of Management and Budget and are part
of the DHS Performance and Accountability Report (PAR).
The performance indicators include:
* Outcome: (I) number of foreign mitigated examinations by category;
and (2) number of investigative cases initiated due to CSI intelligence.
* Output: (1) number of intelligence reports based on CSI foreign
sources; (2) number of operational CSI ports; (3) number of positive
findings by category; and (4) percentage of worldwide U.S. ”destined
containers processed through CSI ports.
* Efficiency: average cost per CSI port to achieve operational status.
Due Date: Completed
Thank you again for the opportunity to provide comments to the draft
report.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix III: Container Security Initiative Seaports:
This appendix provides information on the 58 foreign seaports
participating in CBP's Container Security Initiative (CSI). According
to CBP, CSI was operating in 58 foreign seaports by the end of
September 2007. Table 2 lists the CSI seaports according to the date
when the seaports began conducting CSI operations, shows the phase (I,
II, or III) in which specific seaports were selected for participation
in CSI, the volume of U.S.-bound shipments passing through the seaport
in fiscal year 2007, and specifies which seaports are participating in
the Department of Energy's (DOE) Megaports Initiative and in CBP's
Secure Freight Initiative.
Table 2: 58 CSI seaports as of September 2007:
Seaport: Vancouver;
Country: Canada;
CBP selection phase[A]: I;
Date port began CSI operations: 2/20/2002;
Volume of U.S.-bound containers, fiscal year 2006: 102,363;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Halifax;
Country: Canada;
CBP selection phase[A]: I;
Date port began CSI operations: 3/25/2002;
Volume of U.S.-bound containers, fiscal year 2006: 26,228;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Montreal;
Country: Canada;
CBP selection phase[A]: I;
Date port began CSI operations: 3/25/2002;
Volume of U.S.-bound containers, fiscal year 2006: 140,912;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Rotterdam;
Country: Netherlands;
CBP selection phase[A]: I;
Date port began CSI operations: 9/2/2002;
Volume of U.S.-bound containers, fiscal year 2006: 205,461;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Le Havre;
Country: France;
CBP selection phase[A]: I;
Date port began CSI operations: 12/2/2002;
Volume of U.S.-bound containers, fiscal year 2006: 84,634;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Bremerhaven;
Country: Germany;
CBP selection phase[A]: I;
Date port began CSI operations: 2/2/2003;
Volume of U.S.-bound containers, fiscal year 2006: 350,353;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Hamburg;
Country: Germany;
CBP selection phase[A]: I;
Date port began CSI operations: 2/9/2003;
Volume of U.S.-bound containers, fiscal year 2006: 74,776;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Antwerp;
Country: Belgium;
CBP selection phase[A]: I;
Date port began CSI operations: 2/23/2003;
Volume of U.S.-bound containers, fiscal year 2006: 189,466;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Singapore;
Country: Singapore;
CBP selection phase[A]: I;
Date port began CSI operations: 3/10/2003;
Volume of U.S.-bound containers, fiscal year 2006: 376,846;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Yokohama;
Country: Japan;
CBP selection phase[A]: I;
Date port began CSI operations: 3/24/2003;
Volume of U.S.-bound containers, fiscal year 2006: 65,686;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Hong Kong;
Country: [Empty];
CBP selection phase[A]: I;
Date port began CSI operations: 5/5/2003;
Volume of U.S.-bound containers, fiscal year 2006: 1,333,812;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Gothenburg;
Country: Sweden;
CBP selection phase[A]: II;
Date port began CSI operations: 5/23/2003;
Volume of U.S.-bound containers, fiscal year 2006: 16,256;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Felixstowe;
Country: United Kingdom;
CBP selection phase[A]: I;
Date port began CSI operations: 5/24/2003;
Volume of U.S.-bound containers, fiscal year 2006: 75,544;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Genoa;
Country: Italy;
CBP selection phase[A]: I;
Date port began CSI operations: 6/16/2003;
Volume of U.S.-bound containers, fiscal year 2006: 104,332;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: La Spezia;
Country: Italy;
CBP selection phase[A]: I;
Date port began CSI operations: 6/23/2003;
Volume of U.S.-bound containers, fiscal year 2006: 130,515;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Pusan;
Country: South Korea;
CBP selection phase[A]: I;
Date port began CSI operations: 8/4/2003;
Volume of U.S.-bound containers, fiscal year 2006: 610,061;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Durban;
Country: South Africa;
CBP selection phase[A]: II;
Date port began CSI operations: 12/1/2003;
Volume of U.S.-bound containers, fiscal year 2006: 18,060;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Port Klang;
Country: Malaysia;
CBP selection phase[A]: II;
Date port began CSI operations: 3/8/2004;
Volume of U.S.-bound containers, fiscal year 2006: 18,068;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Tokyo;
Country: Japan;
CBP selection phase[A]: I;
Date port began CSI operations: 5/21/2004;
Volume of U.S.-bound containers, fiscal year 2006: 166,560;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Piraeus;
Country: Greece;
CBP selection phase[A]: II;
Date port began CSI operations: 7/27/2004;
Volume of U.S.-bound containers, fiscal year 2006: 6,306;
Seaports participating in DOE's MegaPorts Initiative[C]:[Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Algeciras;
Country: Spain;
CBP selection phase[A]: I;
Date port began CSI operations: 7/30/2004;
Volume of U.S.-bound containers, fiscal year 2006: 38,266;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Kobe;
Country: Japan;
CBP selection phase[A]: I;
Date port began CSI operations: 8/6/2004;
Volume of U.S.-bound containers, fiscal year 2006: 87,688;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Nagoya;
Country: Japan;
CBP selection phase[A]: I;
Date port began CSI operations: 8/6/2004;
Volume of U.S.-bound containers, fiscal year 2006: 75,290;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Laem Chabang;
Country: Thailand;
CBP selection phase[A]: I;
Date port began CSI operations: 8/13/2004;
Volume of U.S.-bound containers, fiscal year 2006: 72,477;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Tanjung Pelepas;
Country: Malaysia;
CBP selection phase[A]: II;
Date port began CSI operations: 8/16/2004;
Volume of U.S.-bound containers, fiscal year 2006: 24,538;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Naples;
Country: Italy; CBP selection phase[A]: II;
Date port began CSI operations: 9/30/2004;
Volume of U.S.-bound containers, fiscal year 2006: 20,281;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Liverpool;
Country: United Kingdom;
CBP selection phase[A]: II;
Date port began CSI operations: 10/19/2004;
Volume of U.S.-bound containers, fiscal year 2006: 38,062;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Thamesport;
Country: United Kingdom;
CBP selection phase[A]: II;
Date port began CSI operations: 10/19/2004;
Volume of U.S.-bound containers, fiscal year 2006: 20,182;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Southampton;
Country: United Kingdom;
CBP selection phase[A]: II;
Date port began CSI operations: 10/19/2004;
Volume of U.S.-bound containers, fiscal year 2006: 31,780;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Tilbury;
Country: United Kingdom;
CBP selection phase[A]: II;
Date port began CSI operations: 10/19/2004;
Volume of U.S.-bound containers, fiscal year 2006: 5,018;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Gioia Tauro;
Country: Italy;
CBP selection phase[A]: II;
Date port began CSI operations: 10/29/2004;
Volume of U.S.-bound containers, fiscal year 2006: 51,664;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Zeebrugge;
Country: Belgium;
CBP selection phase[A]: II;
Date port began CSI operations: 10/29/2004;
Volume of U.S.-bound containers, fiscal year 2006: 13,202;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Livorno;
Country: Italy;
CBP selection phase[A]: II;
Date port began CSI operations: 12/16/2004;
Volume of U.S.-bound containers, fiscal year 2006: 90,073;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Marseille;
Country: France;
CBP selection phase[A]: II;
Date port began CSI operations: 1/7/2005;
Volume of U.S.-bound containers, fiscal year 2006: 21,142;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Dubai;
Country: United Arab Emirates;
CBP selection phase[A]: II;
Date port began CSI operations: 3/26/2005;
Volume of U.S.-bound containers, fiscal year 2006: 11,316;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Shanghai;
Country: China;
CBP selection phase[A]: I;
Date port began CSI operations: 4/12/2005;
Volume of U.S.-bound containers, fiscal year 2006: 1,041,707;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Shenzhen;
Country: China;
CBP selection phase[A]: I;
Date port began CSI operations: 6/24/2005;
Volume of U.S.-bound containers, fiscal year 2006: 1,099,137;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Kao-hsiung;
Country: Taiwan;
CBP selection phase[A]: I;
Date port began CSI operations: 7/25/2005;
Volume of U.S.-bound containers, fiscal year 2006: 780,598;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Santos;
Country: Brazil;
CBP selection phase[A]: II;
Date port began CSI operations: 9/21/2005;
Volume of U.S.-bound containers, fiscal year 2006: 80,146;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Colombo;
Country: Sri Lanka;
CBP selection phase[A]: II;
Date port began CSI operations: 9/29/2005;
Volume of U.S.-bound containers, fiscal year 2006: 97,058;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Buenos Aires;
Country: Argentina;
CBP selection phase[A]: II;
Date port began CSI operations: 11/17/2005;
Volume of U.S.-bound containers, fiscal year 2006: 27,830;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Lisbon;
Country: Portugal;
CBP selection phase[A]: II;
Date port began CSI operations: 12/14/2005;
Volume of U.S.-bound containers, fiscal year 2006: 12,178;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Salalah;
Country: Oman;
CBP selection phase[A]: III;
Date port began CSI operations: 3/8/2006;
Volume of U.S.-bound containers, fiscal year 2006: 81,333;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Puerto Cortes;
Country: Honduras;
CBP selection phase[A]: III;
Date port began CSI operations: 3/25/2006;
Volume of U.S.-bound containers, fiscal year 2006: 77,707;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Chi-lung;
Country: Taiwan;
CBP selection phase[A]: III;
Date port began CSI operations: 9/25/2006;
Volume of U.S.-bound containers, fiscal year 2006: 78,150;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Valencia;
Country: Spain;
CBP selection phase[A]: III;
Date port began CSI operations: 9/25/2006;
Volume of U.S.-bound containers, fiscal year 2006: 64,453;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Caucedo;
Country: Dominican Republic;
CBP selection phase[A]: III;
Date port began CSI operations: 9/26/2006;
Volume of U.S.-bound containers, fiscal year 2006: 24,495;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Barcelona;
Country: Spain;
CBP selection phase[A]: III;
Date port began CSI operations: 9/27/2006;
Volume of U.S.-bound containers, fiscal year 2006: 46,521;
Seaports participating in DOE's MegaPorts Initiative[C]: [Empty];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Kingston;
Country: Jamaica;
CBP selection phase[A]: III;
Date port began CSI operations: 9/28/2006;
Volume of U.S.-bound containers, fiscal year 2006: 54,244;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Freeport;
Country: Bahamas;
CBP selection phase[A]: III;
Date port began CSI operations: 9/29/2006;
Volume of U.S.-bound containers, fiscal year 2006: 91,159;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Qasim;
Country: Pakistan;
CBP selection phase[A]: III;
Date port began CSI operations: 4/30/2007;
Volume of U.S.-bound containers, fiscal year 2006: 2,058;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Check].
Seaport: Balboa;
Country: Panama;
CBP selection phase[A]: III;
Date port began CSI operations: 8/27/2007;
Volume of U.S.-bound containers, fiscal year 2006: 26,543;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Cartagena;
Country: Colombia;
CBP selection phase[A]: III;
Date port began CSI operations: 9/13/2007;
Volume of U.S.-bound containers, fiscal year 2006: 22,081;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Ashod;
Country: Israel;
CBP selection phase[A]: III;
Date port began CSI operations: 9/17/2007;
Volume of U.S.-bound containers, fiscal year 2006: 1996;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Haifa;
Country: Israel;
CBP selection phase[A]: III;
Date port began CSI operations: 9/25/2007;
Volume of U.S.-bound containers, fiscal year 2006: 36,594;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Colon;
Country: Panama;
CBP selection phase[A]: III;
Date port began CSI operations: 9/28/2007;
Volume of U.S.-bound containers, fiscal year 2006: 56,098;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Manzanillo;
Country: Panama;
CBP selection phase[A]: III;
Date port began CSI operations: 9/28/2007;
Volume of U.S.-bound containers, fiscal year 2006: 61,767;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Seaport: Alexandria;
Country: Egypt;
CBP selection phase[A]: III;
Date port began CSI operations: 9/28/2007;
Volume of U.S.-bound containers, fiscal year 2006: 4,397;
Seaports participating in DOE's MegaPorts Initiative[C]: [Check];
Seaports participating in CBP's Secure Freight Initiative[D]: [Empty].
Source: GAO presentation of CBP data.
[A] CBP selected the foreign seaports in three phases, using the
following general selection criteria for each phase: Phase I included
the seaports with the highest volume of shipments to the United States,
and in phases II and III additional factors were considered, such as
strategic threat factors and diplomatic considerations.
[B] As of December 2007, these seaports are in various stages of
implementation of the Megaports Initiative, and the Department of
Energy has signed agreements to begin work and is in various stages of
implementation at seaports in additional countries as well.
[C] Three CSI seaports (Puerto Cortes, Honduras; Southampton, United
Kingdom; and Qasim, Pakistan) participating in the Secure Freight
Initiative will receive integrated technology that includes existing
container scanning technology--such as X-ray and gamma ray scanners
used by host nations at CSI ports--and radiation detection equipment.
The remaining four seaports will receive more limited deployment of
these technologies as part of the pilot program.
[End of table]
[End of section]
Appendix IV: CSI Activities and Equipment:
Targeting and Examining High-risk Containers:
This appendix provides a detailed description of activities and
equipment used at CSI seaports to target and examine container cargo.
CBP targets all of the U.S.-bound containers that pass through CSI
seaports to identify and, where feasible, examine high-risk container
cargo. The container targeting and examination activities conducted at
the foreign seaports for U.S.-bound cargo (exports) are very similar to
activities CBP conducts at domestic seaports for arriving containers
(imports). Figure 8 illustrates the various steps and decision points
involved in targeting and examining high-risk U.S.-bound containers at
CSI seaports.
Figure 27: CSI Process for Targeting and Examining High-risk Containers
Overseas:
[See PDF for image]
This figure is a complex flow-chart of the CSI process for targeting
and examining high-risk containers overseas. There are five paths that
can be followed in the process:
Path One:
CSI team receives information and ATS scores for U.S.-bound shipments;
Shipment information reviewed by CSI team;
Low risk or is further review needed? (if review is needed, proceed in
Path Two; if not, continue Path One)
Low risk;
Container loaded onto vessel.
Path Two:
CSI team receives information and ATS scores for U.S.-bound shipments;
Shipment information reviewed by CSI team;
Low risk or is further review needed?
CSI team conducts research and consults with host government;
Risk level?
CBP refers to host government for examination;
Host government decides about examination (if no, proceed to Path
Three);
If yes, Host government scans high-risk container with nonintrusive
inspection equipment;
Anomaly detected? (if no, proceed to Path Four);
If yes, Host government conducts physical search;
WMD? (if no, proceed to Path Five);
If yes, Host government implements response plan.
Path Three:
CSI team receives information and ATS scores for U.S.-bound shipments;
Shipment information reviewed by CSI team;
Low risk or is further review needed?
CSI team conducts research and consults with host government;
Risk level?
CBP refers to host government for examination;
Host government decides about examination;
- no, Do-not-load order for national security reason; or;
- no, Request exam at U.S. port arrival;
Container loaded onto vessel.
Path Four:
CSI team receives information and ATS scores for U.S.-bound shipments;
Shipment information reviewed by CSI team;
Low risk or is further review needed?
CSI team conducts research and consults with host government;
Risk level?
CBP refers to host government for examination;
Host government decides about examination
If yes, Host government scans high-risk container with nonintrusive
inspection equipment;
Anomaly detected?
No, Container loaded onto vessel.
Path Five:
CSI team receives information and ATS scores for U.S.-bound shipments;
Shipment information reviewed by CSI team;
Low risk or is further review needed?
CSI team conducts research and consults with host government;
Risk level?
CBP refers to host government for examination;
Host government decides about examination
If yes, Host government scans high-risk container with nonintrusive
inspection equipment;
Anomaly detected?
If yes, Host government conducts physical search;
WMD?
No, Container loaded onto vessel.
Source: U.S. Customs and Border Protection.
[End of figure]
Under CSI, the targeting of cargo can include the targeters' review of
the Automated Targeting System (ATS) score and the information on which
it is based, the bills of lading--which include data about the cargo--
and additional information provided by host government
officials.[Footnote 32] CBP targeters at CSI seaports are to access
bills of lading through ATS, a system that automatically uses its
hundreds of rules to check available data for every container arriving
in the United States and assigns a risk score to each cargo
shipment.[Footnote 33] Targeters review the bill of lading, making a
cursory check for discrepancies and anomalies in the name and address
of the importer, the commodity, the cargo description and other data
elements. On the basis of the initial review of the bill of lading, CBP
officials are to either (1) categorize the cargo as low risk, in which
case, the container holding the cargo is loaded onto the departing
vessel without being examined, or (2) conduct further research in order
to properly characterize the risk level of the cargo. Further research
entails targeters using automated resources, such as the Treasury
Enforcement Communication System or AutoTrack, as well as nonautomated
resources, such as information provided by host government officials,
to obtain applicable information to determine the validity of the
shipment. Further research may also be conducted by the team's
intelligence research specialist. After further research is completed,
CBP officials are to characterize the cargo as either (1) low risk, in
which case it is loaded onto the departing vessel without being
examined, or (2) high-risk, in which case it is referred to host
government officials for concurrence to examine. Since CBP officials do
not have the legal authority to examine U.S.-bound containers in
foreign seaports, the host government customs officials conduct the
examinations.
Host government officials can respond to the referrals for examination
in one of three ways--cargo is examined or the request is either waived
or denied. After receiving a referral from CSI teams, host customs
officials are to review the bill of lading and the reasons for the
referrals to determine whether or not to examine the container cargo.
Some host governments collect intelligence information on U.S.-bound
cargo independent of CSI, which host officials also consider in
decisions of whether to examine the referred cargo. If host government
officials agree that the cargo is high-risk, they will proceed with an
examination. According to CBP, in general, CSI team members are to
observe the examinations and review and document the results. On the
basis of the results of a nonintrusive examination, such as if an
anomaly is apparent in the image of the container, the host government
and CBP officials must decide whether the host government will conduct
a physical examination of the a container.
Alternatively, the CSI team may waive an examination referral if (1)
host government officials provide the CSI team with additional
information that lowers the risk level of the cargo or (2) logistics
prohibit an examination, such as if the cargo container were already
loaded on the departing vessel. Finally, if the host government
officials determine, on the basis of their review, that the cargo is
not high-risk, they will deny examination of the cargo. For any high-
risk cargo for which an examination is waived or denied, CSI teams are
to place a domestic hold on the cargo, so that an examination will be
conducted upon arriving in the United States. However, if CSI team
members are adamant that a cargo container poses an imminent risk to
the carrier or U.S. seaport of arrival but cannot otherwise convince
the host officials to examine the container, CSI team members are to
contact and coordinate with the NTCC to issue a do-not-load order for
national security. According to CBP officials, this order advises the
carrier that the specified container will not be permitted to be
unloaded in the United States until a time when any associated imminent
risk to the cargo container is neutralized. Once the risk is
neutralized, the container is to be loaded back onto the carrier and
placed on hold for a domestic examination. According to CBP officials,
this type of do-not-load order for national security has been
implemented six times since the inception of CSI.
Equipment Used to Conduct Examinations of Cargo Containers:
There are generally two types of CSI cargo container examinations--
scanning with nonintrusive inspection equipment and physical
searches.For scanning cargo containers, there are two basic types of
nonintrusive inspection equipment currently used at CSI seaports: (1)
radiation detection equipment and (2) imaging inspection equipment,
which may use X-rays or gamma rays. Radiation detection equipment, such
as a radiation portal monitor (RPM) and radiation isotope identifier
devices (RIID) detects the presence of radioactive material that may
originate from a container. However, only the RIID can determine
whether the type of radiation emitted by the material actually poses a
threat or is a normal emission of radiation, such as that found in
ceramic tile. We observed at a domestic and a foreign seaport that
generally if radioactive emissions are detected from a cargo container,
customs officials will use a RIID (shown in fig. 9), to determine
whether the radiation being emitted poses a threat.
Figure 9: CBP Official Using Radiation Isotope Identifier Device to
Examine Container at CSI Seaport:
[See PDF for image]
This figure is a photograph of a CBP Official using a radiation isotope
identifier device to examine a container at a CSI Seaport.
Source: GAO.
[End of figure]
The second type of equipment, referred to as imaging equipment, uses X-
ray or gamma ray technology to scan a container and create images of
the container's contents without opening the container. CBP officials,
along with host government officials, may review the images produced
with the X-ray or gamma ray equipment to detect anomalies that may
indicate the presence of WMD. Figure 10 shows a sample image produced
by this type of equipment.
Figure 10: Commercial Sample Image Produced by Nonintrusive Imaging X-
ray Equipment of a Container Loaded on a Truck Trailer:
[See PDF for image]
This figure is a copy of a sample commercial image produced by
nonintrusive imaging x-ray equipment of a container loaded on a truck
trailer.
Source: Host government customs organizations.
[End of figure]
The capabilities of nonintrusive imaging inspection equipment vary by
manufacturer and model. In May 2005, CBP defined minimum performance
capabilities to evaluate the quality and performance of the
nonintrusive imaging inspection equipment being considered for use at
domestic seaports. The domestic standards set baseline performance
requirements for such things as the ability of nonintrusive inspection
equipment to identify images through steel shielding (referred to as
penetration) or the ability to scan an amount of containers in a given
time (referred to as throughput).
[End of section]
Appendix V: CSI Performance Measures:
This appendix provides information on the CSI performance measures used
by CBP. Table 3 describes the performance measures CBP is currently
using to report the overall performance of the CSI program, the linkage
between performance measures and CSI goals, the performance targets
established, and the recent results collected for each measure. In
addition, since our 2005 report, CBP has identified performance
measures one, two and three below as its proxy measures used in place
of a measure for program outcomes, given the difficulty in measuring
the deterrent effect of the program.
Table 3: CSI Performance Measures:
Performance measure number[A]:
1[C];
Performance measures: Percentage of worldwide United States destined
containers processed through CSI seaports[B];
Description of performance measures: Percentage of total U.S.-bound
containers that pass through CSI seaports, where actions are taken to
detect and prevent WMDs from leaving the foreign seaports;
CSI goals associated with specific performance measures: Goal 1:
securing U.S. borders;
Performance targets and actual results of measures, by fiscal year:
Targets: 2010: 86%;
Performance targets and actual results of measures, by fiscal year:
Results: 2007: 86%.
Performance measure number[A]:
2[C];
Performance measures: Number of foreign mitigated examinations by
category;
Description of performance measures: Number of container examinations
determined to be unnecessary, and thus waived, due to information
provided by foreign customs administrations. Developed to quantify
whether co-locating CBP officials at CSI seaports increases information
sharing and collaboration;
CSI goals associated with specific performance measures: Goal 1:
securing U.S. borders;
Performance targets and actual results of measures, by fiscal year:
Targets: 2006: 24,000;
Performance targets and actual results of measures, by fiscal year:
Results: 2006: 47,630.
Performance measure number[A]:
2[C];
Performance measures: Number of foreign mitigated examinations by
category;
Description of performance measures: Number of container examinations
determined to be unnecessary, and thus waived, due to information
provided by foreign customs administrations. Developed to quantify
whether co-locating CBP officials at CSI seaports increases information
sharing and collaboration;
CSI goals associated with specific performance measures: Goal 2:
building a robust CSI cargo security system;
Performance targets and actual results of measures, by fiscal year:
Targets: No target established;
Performance targets and actual results of measures, by fiscal year:
Results: 2007: 18,404.
Performance measure number[A]:
3[C];
Performance measures: Number of intelligence reports based on CSI
foreign sources; Description of performance measures: Number of
intelligence reports that CSI teams disseminate to other CSI and CBP
offices after researching information provided by CSI foreign sources.
Intended to measure whether having CBP officials located at foreign
seaports leads to increased collaboration with foreign customs
officials;
CSI goals associated with specific performance measures: Goal 1:
securing U.S. borders; Goal 2: building a robust CSI cargo security
system; Goal 3: protecting and facilitating trade;
Performance targets and actual results of measures, by fiscal year:
Targets: No target established;
Performance targets and actual results of measures, by fiscal year:
Results: 2007: 138.
Performance measure number[A]:
4;
Performance measures: Number of operational CSI seaports;
Description of performance measures: Total number of seaports where CSI
has been implemented and is operating;
CSI goals associated with specific performance measures: Goal 2:
building a robust CSI cargo security system;
Performance targets and actual results of measures, by fiscal year:
Targets: 2006: 50;
Performance targets and actual results of measures, by fiscal year:
Results: 2006: 50.
Performance measure number[A]:
4;
Performance measures: Number of operational CSI seaports;
Description of performance measures: Total number of seaports where CSI
has been implemented and is operating;
CSI goals associated with specific performance measures: Goal 3:
protecting and facilitating trade;
Performance targets and actual results of measures, by fiscal year:
Targets: 2007: 58;
Performance targets and actual results of measures, by fiscal year:
Results: 2007: 58.
Performance measure number[A]:
5;
Performance measures: Number of investigative cases initiated due to
CSI intelligence;
Description of performance measures: Number of investigative cases
opened either in the United States or at a foreign location due to
intelligence gathered by CSI staff at foreign port locations;
CSI goals associated with specific performance measures: Goal 1:
securing U.S. borders;
Performance targets and actual results of measures, by fiscal year:
Targets: 2006: 48;
Performance targets and actual results of measures, by fiscal year:
Results: 2006: 155.
Performance measure number[A]:
5;
Performance measures: Number of investigative cases initiated due to
CSI intelligence;
Description of performance measures: Number of investigative cases
opened either in the United States or at a foreign location due to
intelligence gathered by CSI staff at foreign port locations;
CSI goals associated with specific performance measures: Goal 3:
protecting and facilitating trade;
Performance targets and actual results of measures, by fiscal year:
Targets: 2007: No target established;
Performance targets and actual results of measures, by fiscal year:
Results: 2007: 135.
Performance measure number[A]:
6;
Performance measures: Number of positive findings by category;
Description of performance measures: Number of foreign and domestic
positive findings in U.S.-bound containers in which there was
participation from CSI teams;
CSI goals associated with specific performance measures: Goal 1:
securing U.S. borders; Goal 3: protecting and facilitating trade;
Performance targets and actual results of measures, by fiscal year:
Targets: No target established;
Performance targets and actual results of measures, by fiscal year:
Results: 2007: 0.
Source: GAO presentation of data reported by CBP.
[A] The CSI strategic plan includes seven performance measures, but
according to CBP officials, the agency is no longer using its cost
efficiency measure, which tracked the expense involved in integrating a
new foreign seaport into the CSI program. CBP officials stated that
they did not plan to establish a cost efficiency measure for ongoing
CSI seaport operations because the seaports differed greatly in their
costs.
[B] CBP defines 'processing' to include any of the following CSI
activities: screening U.S. destined cargo using ATS; conducting further
research; collaborating with host government officials; or examining
the container.
[C] These three performance measures are those CBP identified as
proxies for program outcomes.
[End of table]
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
Stephen L. Caldwell, Director, Homeland Security and Justice Issues,
(202) 512-9610, caldwells@gao.gov.
Staff Acknowledgments:
This report was prepared under the direction of Christine A. Fossett,
Assistant Director, Homeland Security and Justice Issues. Key
contributions to this report also included Amy Bernstein, Fredrick
Berry, Yecenia Camarillo, Frances Cook, Christopher Conrad, Wendy Dye,
Kathryn Godfrey, Valerie Kasindi, Stanley Kostyla, Matthew Lee,
Frederick Lyles, Robert Rivas, and Leslie Sarapu.
[End of section]
Related GAO Products:
Maritime Security: The SAFE Port Act: Status and Implementation One
Year Later. GAO-08-126T. Washington, D.C.: October 30, 2007.
Maritime Security: One Year Later: A Progress Report on the SAFE Port
Act. GAO-08-171T. Washington, D.C.: October 16, 2007.
Maritime Security: The SAFE Port Act and Efforts to Secure Our Nation's
Seaports. GAO-08-86T. Washington, D.C.: October 4, 2007.
Combating Nuclear Smuggling: Additional Actions Needed to Ensure
Adequate Testing of Next Generation Radiation Detection Equipment. GAO-
07-1247T. Washington, D.C.: September 18, 2007.
Maritime Security: Observations on Selected Aspects of the SAFE Port
Act. GAO-07-754T. April 26, 2007.
Customs Revenue: Customs and Border Protection Needs to Improve
Workforce Planning and Accountability. GAO-07-529. Washington, D.C.:
April 12, 2007.
Cargo Container Inspections: Preliminary Observations on the Status of
Efforts to Improve the Automated Targeting System. GAO-06-591T.
Washington, D.C.: March 30, 2006.
Combating Nuclear Smuggling: Efforts to Deploy Radiation Detection
Equipment in the United States and in Other Countries. GAO-05-840T.
Washington, D.C.: June 21, 2005.
Container Security: A Flexible Staffing Model and Minimum Equipment
Requirements Would Improve Overseas Targeting and Inspection Efforts.
GAO-05-557. Washington, D.C.: April 26, 2005.
Homeland Security: Key Cargo Security Programs Can Be Improved. GAO-05-
466T. Washington, D.C.: May 26, 2005.
Maritime Security: Enhancements Made, but Implementation and
Sustainability Remain Key Challenges. GAO-05-448T. Washington, D.C.:
May 17, 2005.
Cargo Security: Partnership Program Grants Importers Reduced Scrutiny
with Limited Assurance of Improved Security. GAO-05-404. Washington,
D.C.: March 11, 2005.
Preventing Nuclear Smuggling: DOE Has Made Limited Progress in
Installing Radiation Detection Equipment at Highest Priority Foreign
Seaports. GAO-05-375. Washington, D.C.: March 31, 2005.
Homeland Security: Process for Reporting Lessons Learned from Seaport
Exercises Needs Further Attention. GAO-05-170. Washington, D.C.:
January 14, 2005.
Port Security: Better Planning Needed to Develop and Operate Maritime
Worker Identification Card Program. GAO-05-106. Washington, D.C.:
December 10, 2004.
Maritime Security: Substantial Work Remains to Translate New Planning
Requirements into Effective Port Security. GAO-04-838. Washington,
D.C.: June 30, 2004.
Homeland Security: Summary of Challenges Faced in Targeting Oceangoing
Cargo Containers for Inspection. GAO-04-557T. Washington, D.C.: March
31, 2004.
Container Security: Expansion of Key Customs Programs Will Require
Greater Attention to Critical Success Factors. GAO-03-770. Washington,
D.C.: July 25, 2003.
[End of section]
Footnotes:
[1] Pub. L. No. 109-347, 120 Stat. 1884 (2006).
[2] Pub. L. No. 110-53, § 1701(a) 121 Stat. 266, 489-90 (2007)
(amending 6 U.S.C. § 982(b)). Also, see GAO, Maritime Security:
Maritime Security: The SAFE Port Act: Status and Implementation One
Year Later. GAO-08-126T. (Washington, D.C.: Oct. 30, 2007), mainly
pages 31 to 35, and 44 to 48 for more detail on the requirements
included in the SAFE Port and 9/11 Acts that affect the CSI program.
[3] GAO, Container Security: A Flexible Staffing Model and Minimum
Equipment Requirements Would Improve Overseas Targeting and Inspection
Efforts, GAO-05-557 (Washington, D.C.: Apr. 26, 2005), and GAO,
Container Security: Expansion of Key Customs Programs Will Require
Greater Attention to Critical Success Factors, GAO-03-770 (Washington,
D.C.: July 25, 2003).
[4] At the time of our engagement, we met with officials from the NTC.
The NTC was established in response to the need for proactive targeting
aimed to prevent acts of terror and to seize, deter and disrupt
terrorists and/or implements of terror. The NTC originally combined
both passenger and cargo targeting in one facility. It was later
divided into the National Targeting Center - Cargo (NTCC) and the
National Targeting Center - Passenger (NTCP). By convention, we will
use NTCC in our references since its mission is to support CBP cargo
targeting operations.
[5] We selected the terms for this report based on definitions provided
in the SAFE Port Act and in consultation with CBP. Also, see appendix
IV for more details about these CSI activities.
[6] Pub. L. No. 103-62, 107 Stat. 285.
[7] According to CBP, the remaining 14 percent of U.S.-bound containers
that do not pass though CSI seaports are targeted by CBP officials at
the NTCC to identify high-risk container shipments, and containers
would be examined upon arrival at U.S. seaports if deemed necessary.
[8] The increase in the percentage of total U.S.-bound containers
passing through CSI seaports is not proportional to the number of CSI
seaports in the program because the volume of U.S.-bound containers
varies from seaport to seaport (and year to year). Appendix III
provides details on when specific foreign seaports began conducting CSI
operations.
[9] According to CBP officials, due to logistics such as the time
necessary for negotiations with host governments and staffing CSI teams
in foreign countries, CSI seaports selected in phases one and two
sometimes did not begin operations until later selection phases were
underway.
[10] According to CBP, phase I included three Canadian seaports at
which there was already a customs relationship with the United States.
[11] CBP reported that NTCC targeters assist the CSI teams at high-
volume seaports to help ensure all containers that pass through CSI
seaports are targeted.
[12] CBP's staffing model calculates the number of officers required at
a CSI seaport as equal to the annual volume of containers shipped to
the United States divided by 64,350 (half the number of containers a
CSI team member should be able to target in a given year) plus or minus
the level of risk associated with that CSI seaport.
[13] Bills of lading are documents issued by carriers describing cargo
in a shipment, details of the intended voyage, and the conditions of
transportation.
[14] Host nations may limit the number of CSI personnel to less than
optimum per the CSI staffing model. According to CBP officials, since
2005, CBP has reported it is unable to staff the CSI teams at the
levels called for in the CSI staffing model because of diplomatic and
practical considerations. For example, the host government or the U.S.
Department of State can restrict the size of the CSI teams located at
foreign seaports.
[15] Permanent recruitment for all overseas positions requires DHS and
State Department approval through the National Security Decision
Directive 38 (NSDD38) process. The NSDD38 provides Chiefs of Mission
the authority to determine the size, composition, and mandate of
personnel operating under their authority. The NSDD38 process is
required whenever a requesting agency is establishing or abolishing an
activity, and changing the size, composition, or mandate of full-time
permanent direct-hire positions.
[16] The CSI human capital plan states that CBP has relied on CBP
officers on temporary duty at the NTCC for CSI duties.
[17] GAO, Overseas Presence: Framework for Assessing Embassy Staff
Levels Can Support Rightsizing Initiatives, GAO-02-780 (Washington,
D.C.: July 2002).
[18] The methods we used to evaluate CBP information in CSI team
evaluations and to observe operations at CSI seaports we visited are
described in appendix I.
[19] According to CBP, all permanent CSI staff deployed at CSI seaports
receive some foreign language training. However, a minimum proficiency
in the language is not required.
[20] We use the term "examination system" to refer to the overall
equipment, people, and processes used by any country to assess goods
leaving or entering their seaports. In the context of CSI, U.S. and
host government officials share the role of assessing goods leaving the
seaports of countries participating in CSI. CSI teams at CSI seaports
are responsible for targeting high-risk containers and other tasks,
whereas host government customs officials examine containers by
scanning a container with nonintrusive inspection equipment, a physical
search of the container's contents, or both.
[21] This sample was composed of all of the evaluations that had been
conducted using the CSITE tool at the time of our review, the
evaluations that directly preceded them chronologically (where
available), and one evaluation from each additional seaport for which
we had documentation. See appendix I for more details about our
selection methodology.
[22] This provision appears to refer to the Framework of Standards to
Secure and Facilitate Global Trade, commonly referred to as the SAFE
Framework, which was adopted by the member countries of the World
Customs Organization, including the United States, in June 2005. As of
September 11, 2007, 148 member countries had signed letters of intent
to implement the SAFE Framework.
[23] There are two types of nonintrusive inspection equipment currently
used at CSI seaports: (1) radiation detection equipment and (2) imaging
inspection equipment, which may use X-rays or gamma rays. Radiation
detection equipment, such as a radiation portal monitor, detects
radioactive emissions that may originate from a container, indicating
the presence of radiological material.
[24] The act stated that the technical criteria and operating
procedures should not be designed to conflict with the sovereignty of
host countries, but it did not address host government sovereignty
related to requirements for CSI seaports to operate the equipment in
accordance with the criteria and procedures.
[25] According to CBP, containers are generally not reexamined in the
United States unless new information is provided about risks or threats
associated with the cargo, such as information related to its point of
origin or some similar factor.
[26] GAO, Internal Control: Standards for Internal Control in the
Federal Government. GAO/AIMD-00-21.3.1. Washington, D.C.: November1999.
[27] GAO, Executive Guide: Effectively Implementing the Government
Performance and Results Act. GAO/GGD-96-118. Washington, D.C.: June
1996.
[28] Specifically, CBP stopped including the number of container
examinations that were not conducted because the host government denied
the request or because logistical challenges prevented it. As we
reported in 2005, these are not necessarily indicators of unnecessary
examinations that were prevented.
[29] GAO, Tax Administration: IRS Needs to Further Refine Its Tax
Filing Season Performance Measures. GAO-03-143. Washington, D.C.:
November 2002.
[30] Appendix V provides more detail on the CSI performance measures
(including the three proxies for program outcomes), the associated CSI
goals, performance targets, and measured results.
[31] In October of 2001, the U.S. Customs Service established the
Office of Border Security (OBS). In October of 2002, OBS was renamed
the National Targeting Center (NTC) and in January of 2003, was
relocated to Virginia. The NTC was established in response to the need
for proactive targeting aimed to prevent acts of terror and to seize,
deter, and disrupt terrorists and/or implements of terror. The NTC
originally combined both passenger and cargo targeting in one facility.
As the NTC targeting mission and staff expanded, it became obvious that
additional facilities were necessary. On March 26, 2007, NTC Passenger
and Cargo operations were divided. The existing NTC facility became
known as the NTC - Passenger (NTCP). The National Targeting Center -
Cargo (NTCC) began operations within the existing facility until the
NTCC facility construction was completed. On May 14, 2007, staff moved
to the new NTCC facility located approximately a mile from NTCP. The
mission of the NTCC is to coordinate and support CBP cargo targeting
operations. NTCC developed enhanced operations to proactively target
and coordinate examinations of high-risk cargo in all modes; provide
high quality research and support to the Secure freight Initiative
(SFI), Container Security Initiative (CSI), domestic CBP units, and
other government agencies; implement new proactive methodologies and
expand information sharing and partnerships. Liaisons stationed at NTCP
include U.S. Coast Guard, Federal Air Marshals, Federal Bureau of
Investigation, Department of State, Transportation Security
Administration, Immigration and Customs Enforcement, and Financial
Crimes Enforcement Network. Liaisons stationed at NTCC include the Food
and Drug Administration, Department of Agriculture, and the Department
of Commerce. The liaisons provide support to both facilities as needed
but are physically located in one facility.
[32] Bills of lading are documents issued by a carrier describing the
goods, the details of the intended voyage, and the conditions of
transportation.
[33] A risk score is derived from applicable rules that assess the
level of risk for the shipment.
[End of section]
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